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Section 4 - Clinical Governance

Patient safety is of paramount importance within all aspects of prescribing and medicines management. Radiographers must practise within the law, to a high professional standard, and ensure that they strive continuously to improve the quality of care that they offer to patients. Poor professional performance needs to be identified and rectified at an early stage. The guidance in this section will apply alongside any organisational policies and/or procedures that the organisation may have in place.

Practice Guidance 37: Governance Structures

37.1 Employed radiographers will be covered by the appropriate Clinical Governance protocols and procedures of their employer. This will include prescribing analysis and clinical audit. radiographers who are not prescribing within the NHS should ensure that they have appropriate clinical governance procedures in place for the safe use of medicines. Arrangements should be made for:

(a) clear lines of responsibility and accountability for overall quality of clinical care;

(b) development of quality improvement programmes such as
clinical audit, supporting evidence-based practice, implementation of clinical standards, monitoring of clinical care, access to appropriate CPD programmes;

(c) management of risk;

(d) procedures to identify and remedy poor performance.

Practice Guidance 38: Clinical Audit

38.1 You should ensure that there are measures in place to evaluate the safety, effectiveness, appropriateness and acceptability of your prescribing within the clinical governance requirements of the NHS.

38.2 Clinical audit is an important part of clinical governance, as it helps radiographers to monitor their supplementary prescribing activities and to ensure that the patient’s CMP is being followed.

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

38.4 You should ensure that you are supported by a regular (normally at least annually) clinical review of the patient’s progress by the independent prescriber at pre-determined intervals stated in the CMP. This should preferably be a joint review with you and the independent prescriber

38.5 You should consider passing prescribing activity back to the independent prescriber if the clinical reviews are not carried out within a specified interval.

38.6 You should pass prescribing activity back to the independent prescriber if you consider that the patient’s condition no longer falls within your competence.

38.7 In order for the CMP to remain valid, both prescribers are required to record their agreement to a continuing or amended CMP and the patient’s agreement to the continuation of the supplementary prescribing arrangement.

38.8 You should ensure that the prescriptions you write are clear and legible. You should audit how many times a pharmacist contacts you to query what was written.

38.9 Patients’ experiences of radiographer supplementary prescribing are an important part of clinical care, and should be regularly sought.

Practice Guidance 39: Prescribing Analysis

39.1 You should ensure that your prescribing activity is included in the reports on the quality of clinical care to local Clinical Governance Committees or their equivalent.

39.2 You should ensure that you have information about national guidelines (e.g. NICE guidelines, NSFs), local guidelines, local agreements and formularies to ensure you make the best prescribing decision for your patients.

Practice Guidance 40: Risk Management

40.1 You should ensure that you have an appropriate Risk Management programme in place. This should include clinical risk management and patient safety (including the National Patient Safety Agency [NPSA] National Reporting and Learning Scheme), confidentiality, safety of prescription pads and a system for handling errors and complaints.

Practice Guidance 41: Continuing Professional Development

41.1 It is your responsibility to remain up-to-date with appropriate knowledge and skills to enable you to prescribe competently and safely.

41.2 You should ensure that your CPD is in line with your current or future practice, including your role as a prescriber.

41.3 You should record your CPD in a format that easily enables you to demonstrate your fitness to practice as a prescriber.

41.4 You should ensure that you set aside sufficient time to access programmes and resources to meet your CPD needs. This may include Peer Review sessions. You should include reflective learning in your CPD portfolio.

Practice Guidance 42 Poor Performance

42.1 Procedures should be put in place for identifying poor prescribing practice. This could be via peer review processes or pharmacist/medical practitioner feedback. The National Clinical Assessment Service (NCAS) publishes several documents relating to performance issues. Although currently the NCAS service is only available for doctors and dentists, the principles are applicable to other healthcare professionals including physiotherapists. Further information is available at under ‘Key Publications’ and ‘Toolkit’.

Practice Guidance 43: Security of NHS Prescription Pads

43.1 The security of prescription pads is your responsibility and the responsibility of the NHS organisation. You must take all reasonable and responsible steps to prevent loss or inappropriate use. You should only use one prescription pad at a time.

43.2 You should keep a record of the first and last serial number of the prescriptions in any pads issued to you.

43.3 At the end of each working day you should record the serial number of the first remaining prescription in your current pad. If your current pad is lost or stolen after you last used it, the relevant serial numbers of unused prescriptions must be reported.

43.4 Prescription pads should be stored in locked areas when not in use. You should not store prescription pads away from your place of work.

43.5 Blank prescription forms should never be pre-signed and prescription pads never left unattended.

43.6 You should report immediately any suspected loss or theft of prescription forms to whoever issued them to you and to the local fraud specialist or equivalent. You should give details of the number of prescription forms lost/stolen, their serial numbers and where and when they were lost/stolen.

43.7 Detailed Guidance can be found in ‘NHS Security Management Service- Security of Prescription Forms Guidance, October 2009.

44.1 If you have a commercial or financial interest in any pharmaceutical product or company then you should ensure that your patients have access to this information where relevant, and you should ensure that your interest does not affect your ability to prescribe in the patient’s best interest alone.

44.2 You must not allow your own, or your employer’s (if applicable) commercial or financial interests in a pharmaceutical company or product influence the way you advise your patients.

44.3 You must declare any conflict of interest in a ‘register of interests’ either within your personal portfolio, or within your employers Hospitality Register which should be produced on request for audit purposes.

Practice Guidance 45: Gifts and Benefits

45.1 You must make your choice of medicinal product for the patient based solely on clinical suitability and cost effectiveness.

45.2 The advertising and promotion of medicines is strictly regulated by the Medicines (Advertising) Regulations 1994. Personal gifts are forbidden and it is an offence to solicit or accept a gift or inducement to influence your prescribing patterns. Companies may offer hospitality for a professional or scientific meeting, but such hospitality must be reasonable in level, and subordinate to, the main purpose of the meeting. This legislation is enforced by the MHRA.

45.3 You must follow your employer’s policy on receiving gifts and hospitality. If you do not have an employer you must consider whether it is appropriate to accept gifts or hospitality in response to your prescribing activities.

Practice Guidance 46: NHS/ Private Practice Prescribing Boundaries

46.1 You must not ask the patient’s GP to prescribe medicines at NHS expense which are subsequently to be administered as part of private healthcare provision. If you do ask a GP to do this, they are within their rights to refuse to do this.

Practice Guidance 47: Checking Registrations and Annotations

47.1 You should provide evidence of your status as a prescriber annually to your employer / those using your prescribing services.

47.2 You must only prescribe in accordance with the type of annotation awarded to you.

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