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Introduction

This practice guidance provides information which should underpin the decision-making and actions of radiographers who are annotated with the Health and Care Professions Council (HCPC), either as radiographer independent and/or supplementary prescribers.

This document is guidance. Guidance is information which a radiographer has a duty to consider and is expected to take into account as part of their decision-making process. This document provides advice on the behaviours and conduct expected of radiographers who are annotated on the HCPC register as an independent and/or supplementary prescriber. Throughout the document, the use of the word ‘must’ indicates a legal and/or regulatory requirement and describes a mandatory action and/or behaviour. The use of the word ‘should’ indicates behaviours and/or actions that would be expected to occur in all normal circumstances. Each section of this guidance carries equal weight and the document is not ordered in any priority.

If a radiographer prescriber deviates from the guidance in this document, the clinical judgment for so doing should be carefully recorded. You should comply with this practice guidance, other guidance issued by the Society and College of Radiographers (SCoR) and with any statutory requirements applicable to your prescribing practice. Failure to do so may put your HCPC registration at risk if concerns are raised about your fitness-to-practise. A radiographer prescriber will be expected to justify any decision to act outside the terms of this guidance and if they undertake a course of action not recommended herein, there must be robust reasons for doing so.

The advice in this document applies to all sectors of health and social care provision in the United Kingdom where prescribing activities occur, as permitted by relevant laws in each of the Home Countries separately. The law may not be comparable across England, Scotland, Wales and Northern Ireland. It is up to the individual to satisfy themselves of the law within the UK country they work and that good governance procedures are in place in their workplace setting.

At the current time, prescribing is not permitted by radiographers outside the UK and therefore a radiographer permitted to independently and/or supplementary prescribe in the UK cannot perform this activity outside UK jurisdiction.

N.B. This practice guidance document primarily focuses on prescribing. There are some references to associated activities related to supply and administration although this has been reduced to a minimum, and only where context is necessary.

Types of radiographer prescribing

From 2005 both diagnostic and therapeutic radiographers could qualify as supplementary prescribers (SP) and from 2016 therapeutic radiographers are able to qualify as independent prescribers (IP).

Appropriately qualified radiographers who are registered with the HCPC will have their HCPC entry annotated to describe their status as a prescriber once they have completed a HCPC approved non-medical prescribing course. For the foreseeable future, the HCPC will annotate the SP and IP qualifications separately.

Radiographers qualified as supplementary prescribers will be annotated as SP only. A supplementary prescriber can only prescribe under a Clinical Management Plan (CMP); they cannot prescribe independently. Therapeutic radiographers qualified as both independent and supplementary prescribers will have a dual SP/IP annotation. Therapeutic radiographer supplementary prescribers will be able to undertake a conversion course to add IP to their annotation.

Standards for prescribing

The HCPC defines the standards that are required for independent prescribing by physiotherapists, podiatrists and therapeutic radiographers, and supplementary prescribing by both diagnostic and therapeutic radiographers, podiatrists, physiotherapists and dietitians. These proficiencies are in addition to those that apply to non-prescribing radiography practice.

http://www.hcpc-uk.org/publications/standards/

The scope of radiography prescribing

Radiographers are pivotal to delivering fast and reliable diagnoses of disease, as well as curative and palliative treatment and care for patients with cancer. The purpose of individual radiographer prescribing is to support and enhance the delivery of interventions to patients within imaging and cancer care. The breadth of the profession as a whole is vast and encompasses the diagnosis and treatment of a range of disorders and diseases using ionising and non-ionising radiation. The radiography workforce delivers diagnostic imaging and radiotherapy services in a range of health and social care settings across the UK. A large majority of patients will be referred for imaging during their treatment and radiographers are key to the delivery of successful clinical outcomes.

Radiographer prescribers should not be asked to prescribe for patients to make up for short-falls in other professional prescribing groups.

Individual radiographers will develop their own scope of practice as they determine, depending on their role and the demands of service. Due to the diverse nature of the profession, while a diagnostic and a therapeutic radiographer may not have an individual overlap of skills, they both sit underneath the overall umbrella of their profession by a shared use of ionising and non-ionising radiation to image and/or treat the patient.  

Diagnostic radiographers work mainly within the imaging departments of hospitals, each of which encompasses a wide range of different imaging modalities, eg ultrasound, magnetic resonance imaging (MRI), computed tomography (CT), radionuclide imaging (RNI) and conventional (plain film) x-rays (either static or dynamic imaging). All of these imaging modalities may involve the administration of contrast agents and associated medicines in order to enhance structures and, show function or as a treatment (interventional radiography). Diagnostic radiographers are experts in drug interactions with imaging contrast media. 

Therapeutic radiographers: Due to their degree-qualified training solely in oncology, therapeutic radiographers are uniquely qualified to undertake this role and their interventions can deliver treatments and cures for cancers. The most commonly treated cancers are breast and prostate cancers, followed by lung cancer. Therapeutic radiographers play a vital role in the delivery of radiotherapy services and are extensively involved at all stages of the patients' cancer journey. They are the only healthcare professionals qualified to plan and deliver radiotherapy. Therapeutic radiographers are responsible for the planning and delivery of accurate treatments using a wide range of technical equipment. The accuracy of this treatment is critical in order to treat the tumour and destroy the diseased tissue, while minimising the amount of exposure to surrounding healthy tissue. Radiotherapy may be used to shrink a cancer before surgery, reduce the risk of a cancer recurring after surgery and to complement or enhance the effects of chemotherapy. It can be used with the intent to destroy the cancer and cure the patient or, when a cure is not possible, palliative radiotherapy may be used with the aim of relieving symptoms such as pain in order to improve the quality at the end of the patient’s life. 

Radiographers are not permitted to prescribe medicines for animals.

The scope of independent prescribing practice by therapeutic radiographers will be:

The therapeutic radiographer independent prescriber may prescribe any licensed medicine, within national and local guidelines, for any condition, the practitioner’s area of expertise and competence, and the overarching framework of treatment of cancer. Subject to approval, they may also in the future be able to prescribe from a restricted list of controlled drugs.

Scope of practice and competency in prescribing

Medicines’ use and prescribing activity is fully accepted as being within the overall scope of the profession as a whole. It will be part of an advanced practice radiographer’s scope of practice following successful completion of an approved programme.

The post-registration educational programme in prescribing ensures radiographers are equipped with the principles of prescribing to enable them to be safe, effective and cost-effective prescribers. Radiographer prescribers should ensure that they are able to apply the prescribing principles to their own area of practice. Radiographer prescribers must only prescribe within their scope of practice and understand that if they change clinical areas, they will require a period of training before they are competent to prescribe in a new area of practice.

An individual’s scope of radiography practice must fall within the overall scope of the profession; therefore an individual’s radiography-prescribing practice must fall within the overall prescribing scope of the profession. At the current time, prescribing is not permitted by radiographers outside the UK and therefore a radiographer permitted to independently prescribe in the UK cannot perform this activity outside UK jurisdiction.

Prescribers must have sufficient education, training and competence to: 

  • assess a patient’s clinical condition 
  • undertake a thorough history, including medical history and medication history (including over-the-counter medicines and complementary therapies), and allergy status 
  • diagnose where necessary
  • decide on management of the presenting condition and whether or not to prescribe and/or refer
  • identify appropriate products of medication as required 
  • advise the patient on risks, benefits and outcomes of the medication 
  • prescribe if the patient agrees 
  • monitor the patient’s condition, including any response to the medication prescribed 
  • give lifestyle advice as appropriate 
  • refer to other professionals if necessary

Prescribing is a professional skill that applies equally to all professions who undertake such responsibility. There is a unified Competency Framework for all Prescribers10 . The SCoR expects members to be able to demonstrate how they meet this competency framework.

NICE publishes guidelines which offer best practice advice on the care of all people who are using medicines and also those who are receiving suboptimal benefit from medicines. See NICE guidelines [NG5]2:  Medicines optimisation: the safe and effective use of medicines to enable the best possible outcomes

Registration and Professional Indemnity Insurance (PII)

Since July 2014, HCPC registrants have been required to have proof of adequate indemnity to practice in order to maintain registration.

Radiographers who are members of the Society and College of Radiographers (SCoR) benefit from personal Professional Indemnity Insurance (PII) as part of their membership of the SCoR. In order for their PII to be in force (subject to the terms of the policy), the SCoR member must work competently within their own scope of practice and: 

  • Hold current registration with the HCPC 
  • Hold a current SCoR membership in a category that provides PII cover at the time that treatment or advice is given and at the time of the claim
  • Be practising lawfully 
  • Be practising within the overall scope of the profession of radiography

Prescribing is accepted as being within the overall scope of the radiography profession. For the PII to be in force the radiographer must be practising lawfully and therefore they must have an HCPC annotation showing their prescribing status as either an independent and/or supplementary prescriber.

SCoR members do not need to inform the SCoR of their prescribing status, though they must not prescribe until they are satisfied that their HCPC entry has been updated.

Radiographers who are not members of the SCoR will need to ensure that they have adequate insurance or other indemnity arrangements in place for their practice. They may be personally liable for any costs if adequate or appropriate insurance is not in place. Many employers now expect individual health professionals to hold their own personal insurance in addition to any employer vicarious liability insurance that may be in force. Radiographers who wish to join the SCoR in order to gain PII and a variety of other benefits and professional support are very welcome and should contact www.sor.org

For further information about PII see website: https://www.sor.org/being-member/professional-indemnity-insurance

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