The Health and Care Professions Council (HCPC) is seeking the views of stakeholders on standards for prescribing.
Currently, chiropodists/podiatrists, physiotherapists and radiographers may become supplementary prescribers if they complete the appropriate training and have their entry on the Register annotated.
p>The Department of Health announced on 24 July 2012 that legislation will be amended to allow appropriately trained chiropodists/podiatrists and physiotherapists to act as independent prescribers. Chiropodists/podiatrists and physiotherapists will only be able to act as independent prescribers if they complete training in independent prescribing and have their entry on our Register annotated.
The HPC has developed new standards for prescribing, which will apply to both supplementary and independent prescribing. The HPC has divided the standards into two sections. The first section contains standards which education programmes delivering training in prescribing will need to meet. The second section contains standards which individual prescribers will need to meet.
Comments on Health and Care Professions Council Consultation on standards for prescribing
The Royal College of Physicians of Edinburgh is pleased to respond to the Health and Care Professions Council on its Consultation on standards for prescribing.
The College welcomes the proposal that the rights of an independent prescriber be extended to physiotherapists and chiropodists/podiatrists on completion of appropriate training.
The College notes and fully understands the additional responsibilities of independent prescribers compared to supplementary prescribers and believes that the extended roles and expanded training and independence in clinical practice of many physiotherapists and chiropodists/podiatrists makes the independent prescriber role appropriate, and even essential. However, the College is concerned that the standards focus on education providers rather the prescribers themselves; it is the latter that will dictate the safety and effectiveness of the independent prescriber role and the level of detail is significantly less than that in the standards for education providers.
More specific comments follow:
- There is no reference to indicative contact hours/expected duration of training;
- Assessment standards would benefit from being more specific about methodology;
- Objectivity will be difficult to guarantee if there is significant reliance on the supervising practitioner;
- Standards should also be more outcome rather than process focused;
- The only real standard for prescribers around medicines themselves is 1.1 (‘Understand pharmacokinetics and pharmacodynamics’). While this is important, it is but a small part of the understanding required for any prescriber, and particularly an independent prescriber. A supplementary prescriber may hope/infer that their prescribing lead will cover the other relevant issues, but an independent prescriber needs much more understanding to be able to prescribe safely and effectively.
Suggestions for additional standards for independent prescribers
The College suggests that the following additional standards for independent prescribers be considered. The list does not aim to be comprehensive but to act as a catalyst around which other suggestions may congregate.
- understand that a decision to prescribe should be only one part of an overall management plan for an individual patient and that prescribing (and allied issues) should not dominate other treatment interventions;
- understand the modes of action of individual medicines (relevant to the specific prescriber);
- understand that all medicines have both risks and benefits, and that the licensing process has merely defined that the overall benefits outweigh the risks;
- understand the concepts of adverse effects, contra-indications and special precautions of individual medicines, and the consequent issues for prescribers;
- understand the concepts, mechanisms and importance of drug interactions, the need for a full medicines history, and the necessity to factor these issues into safe and effective prescribing;
- understand that patient-specific issues such as education and explanation are key to patient adherence/concordance with therapy and be able to demonstrate skills in patient communication;
- understand the need to report adverse effects of medicines (especially ‘black triangle’ medicines) using the ‘Yellow Card’ scheme and to participate in other forms of information gathering including Phase 4 studies, prescription event monitoring etc;
- understand the need to ensure that prescribing decisions are fully documented and shared with others who may be treating an individual patient;
- understand the roles of national, regional and local prescribing guidelines, protocols and formularies and the need for independent prescribing to work within these frameworks;
- understand the sources of information on medicines relevant to prescribing decisions, including the British National Formulary (BNF), medicines’ SPCs (Summaries of Product Characteristics) and Medicines Information services.
The College hopes these comments and suggestions are helpful in shifting the balance of standards from process to content and outcome, to generate the greatest impact on safe and effective independent prescribers.