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Section 1 – Principles of Good Prescribing Practice

This section provides advice and guidance on prescribing practice. Having achieved the competencies for supplementary prescribing, radiographers are expected to follow this advice in their practice.

As a radiographer supplementary prescriber you should comply with this practice guidance and other guidance issued by the SCoR together with any statutory requirements applicable to your prescribing practice. Failure to do so may put your HPC registration at risk if concerns are raised about your fitness to practice.

The SCoR considers it good practice, that where radiographers are employed, that the employing organisation signs off all protocols and procedures. Where possible radiographer supplementary prescribers should follow organisational level policies and procedures and should only create local department level procedure where no organisational policy or procedure is in existence.

Practice Guidance 1: Licence to Prescribe

1.1 You must only prescribe once you have successfully completed an HPC approved prescribing programme and had your entry on the register of the HPC annotated to show your prescribing status as a supplementary prescriber.

1.2 You should comply with this Practice Guidance, other guidance issued by the SCoR, and with any statutory requirements applicable to your prescribing practice. Failure to do so may put your HPC registration at risk if concerns are raised about your fitness to practise.

1.3 You must only prescribe within your own defined scope of practice and clinical specialty.

1.4 You may prescribe any licensed medicine. You may prescribe controlled drugs as a Supplementary Prescriber if the drugs are listed within a written Clinical Management Plan. You may prescribe unlicensed medicines only when acting as a Supplementary Prescriber acting within a written Clinical Management Plan.

1.5 You must understand which legal framework you are using to supply and administer and/or prescribe medicines, and ensure that those to whom you delegate aspects of supply/administration are aware of under which framework your instruction is given.

Practice Guidance 2: Accountability

2.1 You are professionally accountable for your own prescribing decisions, including actions and omissions. You cannot delegate this accountability to any other person nor can any other person accept accountability on your behalf for your actions. As a supplementary prescriber you are wholly responsible for your decision to prescribe or use the medicines listed within the written CMP. The decision to include medicines in a CMP may be shared between you and the medical prescriber.

2.2 You must only ever prescribe within your level of education, training and competence as a supplementary prescriber, acting in accordance with the HPC Standards of Proficiency and the SoR Code of Conduct and Ethics.

2.3 If you move to another area of practice you must consider the requirements of your new role and only prescribe within your level of education, training and competence for that new speciality. You may need to undertake further training in order to establish your competency to prescribe in your new clinical specialty

2.4 You must inform anyone who needs to know about any limitations to your prescribing practice. In particular, other practitioners with dispensing responsibilities need to know about this. For example, your employer may operate a specific prescribing formulary and may not allow you to prescribe outside of this formulary. This restricted formulary would only apply to your NHS practice for that employer.

2.5 You must inform the relevant authorities if you have any formal regulatory restrictions placed on your prescribing activity, for example, if the HPC forbids you to prescribe controlled drugs or other named drugs.

Practice Guidance 3: Assessment

3.1 As you are accountable for prescribing for the patient you must prescribe only where you have relevant knowledge of the patient’s health and medical history, including their medication history.

3.2 You must know what medication the patient is currently taking (including over the counter [OTC] and herbal preparations) before prescribing medications referred to in the CMP.

3.3 You should take steps to ensure that the patient is not suffering from any medical condition, or receiving any other treatment, that would make the prescription of any medicine unsuitable or dangerous.

3.4 You should ensure that you consider the effects of your patient’s lifestyle which may affect the safety of the medicines you prescribe. This will include:

  • the effects of smoking/caffeine/alcohol
  • the effects of ‘recreational’ or ‘street’ drugs or those used to enhance physical or sporting performance
  • the effects of OTC medicines including herbal preparations.

3.5 Where necessary you should request additional appropriate tests or have access to the results of those tests which are relevant to the presenting condition and/or appropriate to the prescribing decisions to be made in order to assist your prescribing decisions. These may include:

  • blood haematology
  • blood biochemistry tests e.g. liver, thyroid and/or kidney function
  • radiological investigations

3.6 You should regularly monitor and assess the patient’s progress as appropriate to the patient’s condition and the medicines prescribed.

Practice Guidance 4: Clinical Need

4.1 You must only prescribe where you have assessed the patient and there is a genuine clinical need for treatment.

4.2 You may alter the medicine prescribed within the limits set by the CMP if monitoring of the patient’s progress indicates that this is clinically appropriate.

4.3 Within the CMP you must also consider the circumstances in which you may decide to withdraw medication, cease to continue prescribing a named medication or alter the prescribed dose of a medication. Patients may also wish to discuss with you withdrawal from medication at their choice. Any withdrawal from medicines needs to be planned in partnership with the patient and take place over an agreed time period.

4.4 You should prescribe in the patient’s best interests and achieve this by reaching agreement with the patient on the use of any proposed medicine within the CMP. The amount of information you discuss with the patient will vary according to the nature of the patient’s condition, the risks and benefits of the medicine and any alternatives, and the patient’s wishes, but in all circumstances will include the provision of ‘sufficient information’ to allow the patient to make an informed choice i.e. to give their informed consent. You should aim to:

  • establish the patient’s priorities, preferences and concerns
  • discuss alternative treatment options available to the patient
  • satisfy yourself that you have enough relevant information to make a prescribing decision
  • satisfy yourself that the patient understands how to take the medicine as prescribed

4.5 You should never prescribe for your own convenience, or simply because a patient demands that you do.

5.1 You must explain your role as a non-medical prescriber to the patient or their representative. You must provide your patient with ‘sufficient information’ relating to the risks, benefits and significant and material outcomes of the medicines management you are considering as well as the comparative risks of alternative treatment options to medication that may be considered. The provision of ‘sufficient information’ is required to ensure the patient is able to make a decision appropriate for them and thus give ‘informed consent’ to treatment.

5.2 You must be aware of social, cultural and religious differences insofar as they apply to prescribing. 

5.3 You must act in accordance with the Department of Health, SCoR and employer guidance on the obtaining and documentation of consent.

5.4 The patient should be provided, if appropriate, with any relevant Patient Information Leaflet (PIL) about the medicine you propose to prescribe in order to assist them in making an appropriate decision.

5.5 You must make it clear to the patient that prescribing activity cannot be undertaken in isolation. You should inform anyone else who may be in a position to prescribe for that patient of your actions to avoid prescribing errors. This is most likely to be the patient’s general medical practitioner, but may also include other health and social care professionals. If the patient refuses to consent to you sharing such information you must offer an explanation of the risks of not doing so. If the patient continues to refuse to give consent, you must consider which course of action, including to not prescribe, would be in the best interests of the patient. This must be documented in their records.

5.6 The patient should be provided with any relevant Patient Information Leaflet (PIL) about the medicine you propose to prescribe, if appropriate, in order to assist them in making an appropriate decision. In in-patient settings where a PIL may not be routinely supplied, patients can request such information if they wish and should be supplied with the information they require.

5.7 The patient must be clearly informed if the medicine being prescribed is part of a properly conducted clinical research trial and to consider whether they wish to be part of that trial.

Practice Guidance 6: Communication

6.1 You must communicate, using the most appropriate media, effectively with other practitioners involved in the care of the patient. This includes communication across NHS-private practice boundaries where necessary. You must refer the patient to another prescriber when it is necessary to do so.

6.2 Prescribing decisions should be made in partnership with the patient, where practicable to do so. This will include taking into account the patient’s personal views and beliefs and discussing prescribing and medication decisions in relation to these.

6.3 Prescribing is not an activity that occurs in isolation. Prescribing information must be shared with other health professionals who need to know the information for the benefit of the patient and this will include the patient’s GP. You should decide the best methods of sharing this information. Where possible, you should have access to other professionals’ prescribing decisions where they impact upon your own decisions. This will include communication across NHS-private practice boundaries where it is necessary to ensure that clinicians have appropriate information to inform their prescribing practice.

6.4 You must know what medication the patient is currently taking including Over-The-Counter and herbal preparations before prescribing new medications and you must take 12 steps to ensure you have access to the primary source of prescribing information, which is likely to be the GP record.

6.5 Documentation of your prescribing communications should be recorded as described in Practice Guidance 7.

Practice Guidance 7: Record-Keeping

7.1 This practice guidance relates specifically to the record keeping of your prescribing actions. You should refer to other standards and guidance for information relating to clinical record keeping in general.

7.2 Prescribing activity (e.g. writing an FP10, using a hospital based treatment/drug card or using an electronic prescribing application, or a private prescription) must occur at the time of contact with the patient in order to ensure contemporaneous activity is captured in the clinical record.

7.3 Documentation of the prescribing activity should be recorded in clinical records at the time of treatment of the patient. It is not good practice to document prescribing activity after the event e.g. at the end of the clinic session or the end of the day. Only in exceptional circumstances should documentation be delayed, but in any event the delay should not exceed 24 hours.

7.4 In supplementary prescribing, the doctor/dentist and supplementary prescribers must share access to, consult and, wherever possible, use the same common patient record.

7.5 Records should include the prescription details, together with relevant details of the consultation with the patient.

7.6 Your records should show that you have communicated with the primary healthcare record keeper (usually the GP) especially with regard to repeat, ongoing or withdrawn prescriptions. For hospital in-patients this may be in the form of the hospital discharge letter and/or clinic letter.

Practice Guidance 8: Evidence-Based Prescribing

8.1 You should ensure that your prescribing practice is appropriate, responsible and in the patient’s best interests. Every medicine that is prescribable will have an evidence base recommending its use and you should be aware of the current evidence supporting the use of a given medicine.

8.2 You should use national sources of evidence as your primary source of evidence-based prescribing. Such sources include:

  • NICE Guidelines for clinical conditions
  • NICE Guidance for the use of treatments/interventions 
  • Clinical Knowledge Summaries
  • Current edition of the BNF and BNF for Children

8.3 Where you can clearly demonstrate that a national source of evidence is not available, then locally agreed practice based evidence or protocols should be followed.

8.4 You may have a role in helping others to keep up to date and you should share your knowledge with others as appropriate. This will ensure that all prescribing is in accordance with the best available evidence and guidelines.

8.5 You must ensure your prescribing is appropriate and responsible by ensuring you:

  • are familiar with the current national sources of evidence for the medicine
  • are familiar with the current national sources of evidence for the condition you are treating which may also include current evidence for which medicine groups should be used, or not used, and a hierarchy of medicines use
  • have taken an appropriate assessment of the patient
  • have taken into account the patient’s preferences and expressed wishes with regard to medicines use
  • have prescribed the appropriate dose for your patient’s age and weight

Practice Guidance 9: Delegation

9.1 You may delegate the administration of a medicine that you have prescribed to another healthcare worker or to the patient themselves. You remain accountable for your prescribing decision, and you are also accountable for your decision to delegate the task of administration to someone else including the patient. This includes your assessment that the person is competent to carry out the task and has received sufficient training to carry out your instructions. You are not accountable for the outcome of an action performed by another person.

9.2 You may not delegate administration of a medicine that you supply or administer via a PGD. Medicines listed within a PGD can only be administered by the registered health professionals named on the PGD and should never be administrated by assistant practitioners.

9.3 When delegating the administration of a medicine to someone else you should record in the appropriate record:

  • the name and profession to whom you delegated the administration
  • what you have asked them to administer
  • how you have asked them to administer

9.4 Where this information is not clearly identifiable from your written prescription then the information should be separately recorded in the patient record.

9.5 You must provide direct supervision of any post-registration radiographer who is undergoing a period of training in the safe use of medicines or prescribing.

Practice Guidance 10: Information given to patients about their medicines

10.1 Patients, or those authorising treatment on behalf of the patient, should be given sufficient information as they require in order for them to make an informed choice with regard to prescribing decisions. You should include:

  • diagnosis giving rise to prescribing need
  • any known serious or common side effects of the proposed medicine
  • how the medicine works
  • how long to take the medicine for
  • how to stop taking the medicine

10.2 Information provided must be appropriate to the patient’s levels of understanding.

10.3 Where practicable you should support information given to your patients in writing.

10.4 You should tell the patient that their medicine will come supplied with a manufacturer Patient Information Leaflet (PIL) which will give them additional information. In in-patient settings where the PIL is not routinely supplied, patient’s can request such information if they wish.

10.5 You must inform the patient if you propose to prescribe or use any medicine that is unlicensed (including the use of ‘mixed’ medicines), where there is little research or other evidence of current practice to support your proposed use of the medicine, or where the use of the medicine is innovative.

Practice Guidance 11: Clinical Management Plan

Crucial to supplementary prescribing is the Clinical Management Plan (CMP) whose term is defined in law by Section 1(2) of the Medicines (Exemptions and Miscellaneous Amendments) Order, 2009 (No 3062). Regulations provide that a CMP must be in place before supplementary prescribing can go ahead.3

11.1 You must prescribe in accordance with a patient’s individual clinical management plan (CMP). The independent prescriber (doctor or dentist) is responsible for the initial diagnosis and for the setting up of the parameters of the CMP, although they need not have personally set it up.

11.2 The CMP must be agreed by both the independent prescriber and the supplementary prescriber, with the consent of the patient, before supplementary prescribing begins. Agreements must be recorded in the CMP and in the patient record. The CMP will remain in place for an agreed period of time, usually no longer than 12 months. 

11.3 The CMP may include reference to clinical guidelines and guidance as an alternative to listing medicines individually. These referred-to guidelines must be readily accessible by you.

11.4 You have discretion in the choice of dosage, frequency, product and other variables in relation to medicines within the limits specified within the CMP.

11.5 You should, with the independent prescriber, jointly carry out formal clinical reviews at predetermined periods both within the lifespan of the CMP and at its culmination. The final review may be undertaken jointly by both prescribers reviewing the patient together; in the event of this not being possible, the independent prescriber should review the patient and then subsequently discuss future patient management with you.

11.6 You must refer the patient back to the independent prescriber should the patient’s circumstances change to the extent that they cannot be managed within the CMP.

11.7 You must never prescribe medication in the absence of a CMP. The independent prescriber may agree verbally to a CMP providing that it is confirmed by fax or secure email before prescribing occurs and formally agreed within two working days.

11.8 The prescribing of a POM by you in your role as a supplementary prescriber outside a CMP constitutes a criminal offence under the terms of the POM Order. Such action could mean that you would be subject to prosecution under the Medicines Act (1968), although it is more likely that action would be taken by the HPC under its Fitness to Practice procedures.

Practice Guidance 12: Transcribing

12.1 In some circumstances you may be asked to transfer medicines information from one document to another, a process known as transcribing. Transcribing should not be a routine or regular occurrence.

12.2 If you transcribe, you are accountable for your actions and omissions and this will include any errors you make in transferring the information from one document to another.

12.3 You should satisfy yourself that transcribing is a necessary activity that cannot be eliminated by reviewing and improving the care pathway. If transcribing must occur, you should ensure that the activity meets local clinical governance requirements.

12.4 Any transcription must include:

  • Patient’s full name
  • Date of birth
  • Name of medicine
  • Drug dosage, strength, timing, frequency and route of administration 

Practice Guidance 13: Electronic Prescribing

13.1 If you prescribe using e-Prescribing software you must also be using a compatible electronic clinical record software package that allows your prescribing activities to be referenced and cross-checked against the main electronic clinical record. The purpose of electronic prescribing is to reduce medicines errors and reduce patient morbidity and mortality; therefore the prescribing record must be linked to the clinical record.

13.2 You may prescribe via computer-generated prescriptions providing the necessary software is available.

13.3 A traceable audit trail of your prescribing actions must be maintained.

13.4 You must never print off blank prescriptions in advance and store them for future use.

Practice Guidance 14: Writing NHS Prescriptions

14.1 In order to write an NHS prescription, the medicine must be permitted to be prescribed at NHS expense. You should check the BNF if you are not sure if a medicine is available on the NHS. If a medicine is not available at NHS expense, it can only be prescribed against a private prescription

14.2 You and your NHS organisation are responsible for the security of prescription forms.

14.3 Your written prescription must contain the information required by law such as:

  • it must be signed in ink
  • it must contain your name and workplace address
  • the date on which the prescription was signed by you and/or the date after which it can be dispensed
  • your profession
  • the name and address of the patient
  • the age of the patient if they are under 12 years old

14.4 The names of the medicines must be written clearly using approved names only. You must not use abbreviations in the name of the medicine.

14.5 You must only write prescriptions for your NHS patients on forms that have been issued specifically to you that show your name and HPC registration number on them.

14.6 You must sign your prescriptions immediately after they are produced. If this is not possible (e.g. the prescription is printed in a dispensary away from your clinic room), the unsigned prescriptions must be securely stored until you can sign them. You must sign them within 24 hours

14.7 You must never sign blank prescription forms in advance and store them for future use. 

Practice Guidance 15: Writing Private Prescriptions

15.1 Supplementary prescribing may operate in private practice, where any prescription must be in accordance with what has been agreed with the independent prescriber and the patient within the terms of the CMP.

Practice Guidance 16: Reviewing Prescriptions

16.1 You should review a patient’s medication regularly and in particular when you are starting a new medication, stopping a medication or changing a dose of a current medication.

Practice Guidance 17: Repeat Prescriptions

17.1 Repeat prescriptions are valid for six months and, unless specified in writing on the prescription otherwise, the medicine may be dispensed twice within the validity of the prescription (with the exception of contraceptives which may be dispensed six times). You should ensure that you review your patient’s medication at regular intervals to ensure the prescription remains appropriate for your patient’s needs.

17.2 If you issue repeat prescriptions you must ensure that you prescribe safely and responsibly. Before signing repeat prescriptions you must be satisfied that it is safe and appropriate to do so. You should review repeat prescriptions regularly and do not issues medicines for longer than is clinically required. You should ensure the correct dose is prescribed for medicines where the dose varies according to the stage of the treatment.

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