Download document - Castle Point and Rochford CCG

<GP Surgery Name>
Non-Medical Prescribing Policy
Version
1.0
Name of author/job title
Liz Harrison, Quality & Patient Safety Manager for
primary care co-commissioning
Ratified by
CP&R CCG Quality & Governance Committee
Date Ratified
17th March 2016
Review Date
March 2018
Target audience
All practice staff
POLICY STATEMENT
This policy sets out a framework for the development and implementation of non-medical prescribing
within the <GP Surgery Name> practice in order to establish a consistent approach. This policy applies to
all registered nurses and allied health professionals with a non-medical prescribing qualification; employed
or engaged by the GP practice and required to prescribe as part of their role.
EQUALITY IMPACT
<GP Surgery Name> strives to ensure equality of opportunity for all service users, local people and the
workforce. This document has therefore been equality impact assessed to ensure fairness and
consistency for all those covered by it regardless of their individual differences. The results are shown in
the Equality Impact Tool at Appendix A.
DOCUMENT CONTROL
The <GP Surgery Name> Non-Medical Prescribing policy was developed through the Non-Medical
Prescribing Forum. Non-Medical Prescribers (NMPs) across the Castle Point & Rochford locality and the
Medicines Management Team were involved in the development process. Finally the policy was
disseminated to members of the Medicines Management Team and the Non-Medical Prescribing Lead
(Chief Nurse) for ratification.
ASSOCIATED LINKS
Medicines Management guidance is available on the Castle Point & Rochford CCG website via this link
All local medicine and appliance formularies for CP&R are accessible via this link
This BNF online link also leads to the BNF for children and Nurse Prescribers’ Formulary
National Institute for Health and Care Excellence (NICE) guidance link
The NMC Code link
The NMC standards for medicines management link
The NMC standards of proficiency for nurse and midwife prescribers link
The NMC revalidation guidance link
The professional duty of candour guidance link
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Adapted from the University Hospital of South Manchester Community Services NMP policy v1.0 2013
PURPOSE
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To govern the practice of non-medical prescribing within the practice;
To ensure prescribing practice is compatible with the practice’s development plans and is an
appropriate extension of practitioners’ roles;
To ensure that new prescribers are appropriately qualified for the role, work within agreed national
and local policies and are identified within the practice;
To ensure that prescribers are supported in their role and maintain the continued professional
development (CPD);
To set out guidance for how non-medical prescribers will use the clinical record system and
electronic prescribing safely.
ROLES & RESPONSIBILITIES
Non Medical Prescribing Lead
The Chief Nurse for Castle Point & Rochford CCG is the Non-Medical Prescribing Lead and authorised
signatory for approving registration of non-medical prescribers. They have responsibility for:
 Promoting and co-ordinating non-medical prescribing information and communication
 Maintaining a register of non-medical prescribers
 Monitoring clinical governance systems
 Provision of support and training
The Medicines Management Team
The Medicines Management Team are responsible for promoting safe and effective prescribing and
monitor prescribing practices across Castle Point & Rochford CCG, Southend CCG and Southend
University Hospital Foundation Trust.
<GP Surgery Name>
<GP Surgery Name> is responsible for developing and maintaining this Non-Medical Prescribing Policy
and highlighting any queries or concerns to the Non-Medical Prescribing Lead. As the employer <GP
Surgery Name> will hold vicarious liability for their non-medical prescribers.
Line Managers
The Line Manager will ensure that:
 Non-medical prescribing (NMP) is necessary and beneficial to patient care and does not pose
unnecessary risk Only staff who meet the eligibility criteria are supported to undertake training for
NMP
 The staff member has completed the necessary training/courses in order to prescribe and provide
evidence of such to the NMP Lead
 The non-medical prescriber engages in continuing professional development relevant to their
prescribing practice and maintains evidence of such in their professional portfolio
 The non-medical prescriber has read and adheres to this Policy, related national guidance and
legislation
 The non-medical prescriber’s job description includes their role and responsibilities in relation to
NMP. Prescription pads are returned for safe keeping or secure destruction if the staff member is
absent for more than four weeks, e.g. maternity leave, long term sickness absence, termination of
employment.
 Line managers of non-medical prescribers should inform the NMP Lead (Chief Nurse) of any nonmedical prescriber additions/deletions or changes to their information (i.e. change of surname)
Page 2 of 11
Adapted from the University Hospital of South Manchester Community Services NMP policy v1.0 2013
using one of the relevant proformas via this link. As the authorised signatory, the NMP Lead can
register this information with NHS Prescription Services.
The Non-Medical Prescriber
In order to be entitled to prescribe within the organisation, practitioners must be registered as prescribers
with their professional regulator and demonstrate up-to-date clinical competence in their intended field of
prescribing.
The Non-Medical Prescriber will:
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Prescribe in line with organisational formularies and guidelines
Adhere to Trust policies, national/local guidance, and their professional code of conduct
Maintain their registration as a prescriber with their professional regulator and ensure that their role
as a prescriber is clearly described in their job description
Provide evidence-based, safe, effective, cost-effective prescribing for their patients within the
scope of their service, competence and with reference to approved personal / service /
organisational formularies maintain accurate, legible, unambiguous, contemporaneous records of
patient care accept responsibility and accountability for their prescribing decisions and practice
Ensure that patients are aware of the scope and limits of NMP, that they understand their right to
refuse treatment / prescribing from a non-medical prescriber and that the non-medical prescriber
may refer them to other healthcare professionals as necessary
Complete prescriptions legibly and legally, paying particular attention to annotation of designation,
prescriber code, contact number and practice code (where applicable) co-operate with audit,
monitoring and investigations
DEFINITIONS
Community Practitioner Nurse Prescribing
Nurses who have completed a specialist practice programme that includes the V100 module, or who have
completed the standalone V150 module. Prescribing is limited to the Nurse Prescribers’ Formulary for
Community Practitioners. Community Practitioner Nurse Prescribers must only prescribe for patients that
they have assessed. In the event of being requested to prescribe for a patient under the caseload of
another practitioner the prescriber must undertake his/her own assessment.
Supplementary Prescribing
Supplementary prescribing is a voluntary partnership between a responsible medical prescriber (doctor or
dentist), a supplementary prescriber and the patient, to implement an agreed patient specific clinical
management plan (CMP). This mode of prescribing is available to nurses, pharmacists, physiotherapists,
podiatrists, optometrists and radiographers.
There are no legal restrictions on clinical conditions that may be treated under supplementary prescribing,
although it is expected that it would usually be employed in the management of chronic medical
conditions. Supplementary Prescribers may prescribe any medicine, including controlled and unlicensed
drugs, as long as they are specified in the agreed CMP.
The medical prescriber must conduct an initial clinical assessment of patient, provide a diagnosis and
provide advice and support to the supplementary prescriber, as required
A patient-specific clinical management plan (CMP) will be drawn up and agreed by the independent
prescriber, the supplementary prescriber and the patient before supplementary prescribing begins. Both
prescribers must sign the plan and patient consent must be documented.
The CMP must be drawn up using the Practice template, which takes account of legal requirements; all
fields must be completed. All details of the CMP must be reviewed and updated at least once a year and
Page 3 of 11
Adapted from the University Hospital of South Manchester Community Services NMP policy v1.0 2013
the frequency and timing of the review must be specified on the CMP. If either the independent or
supplementary prescriber cease to be involved the patient’s care a new CMP must be agreed between all
three parties before any further prescribing occurs.
The CMP must specify the range of medicines and circumstances and parameters within which the
supplementary prescriber can vary dosage frequency and formulation of medicines identified. It may
include reference to recognised guidelines for a specific condition.
Copies of the agreed CMP must be filed in the patient record and sent to the patient’s GP. Additional
copies may be sent to other health professionals who are involved in the patient’s care where appropriate.
The supplementary prescribing arrangement may be ended at any time, by either prescriber or the patient,
at which time the medical prescriber will resume full responsibility for prescribing.
Independent Prescribing
The prescriber is responsible and accountable for the assessment of patients with undiagnosed or
diagnosed conditions and for decisions about the clinical management required.
Nurses, pharmacists and optometrists may be qualified as independent prescribers. They must have
successfully completed a recognised independent prescribing course and registered their qualification with
their professional body.
Independent prescribers may only prescribe for patients they have assessed. In the event of being
requested to prescribe for a patient under the caseload of another practitioner the independent prescriber
must undertake his/her own assessment.
Nurse and pharmacist independent prescribers may prescribe any medicine (including unlicensed
medicines and controlled drugs) within the scope of their role, their clinical competence and according to
any agreed formularies.
Repeat prescribing
Repeat prescribing is only acceptable where the prescribed drug is within the NMP’s scope of
competence. Non-medical prescribers must not authorise repeat prescriptions for drugs that are out of the
scope of their competence and remit.
It may be more appropriate for chronic medication to be issued by the GP as part of the patient’s routine
repeat prescription.
Off-label / off-licence medicines
Nurse and Pharmacist independent prescribers may prescribe medicines for use outside of their licensed
indications / marketing authorisation (so called ‘off-licence’ or ‘off-label’). In doing so they accept
professional, clinical and legal responsibility and should only prescribe ‘off-label’ where it is accepted
clinical practice. The prescriber must explain the situation to the patient or their guardian/carer/advocate
and clearly document their reasons for prescribing such a medicine and their discussion with the patient.
Supplementary prescribers may prescribe medicines for use outside of their licensed indications /
marketing authorisation (so called ‘off-licence’ or ‘off-label’) as long as it is within the terms of an agreed
clinical management plan. In doing so they accept professional, clinical and legal responsibility and should
only prescribe ‘off-label’ where it is accepted clinical practice. The prescriber must explain the situation to
the patient or their guardian/carer/advocate and clearly document their reasons for prescribing such a
medicine and their discussion with the patient.
Community Practitioner Nurse Prescribers may not prescribe medicines for use outside of their licensed
indications / marketing authorisation with the exception of Nystatin oral suspension, which may be
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Adapted from the University Hospital of South Manchester Community Services NMP policy v1.0 2013
prescribed for children from 28 days of age. The prescriber must explain the situation to the patient or their
guardian/carer/advocate and clearly document their reasons for prescribing such a medicine and their
discussion with the patient.
Unlicensed medicines
Nurse and pharmacist independent prescribers may prescribe unlicensed medicines within their
competence and field of expertise, where it is accepted and evidence-based clinical practice.
Supplementary prescribers may prescribe unlicensed medicines if they form part of an agreed CMP.
The independent / supplementary prescriber remains accountable and liable for prescribing of unlicensed
medicines and should comprehensively document their reasons for prescribing. The patient or patient’s
guardian should be informed and consent obtained for the treatment.
Community Practitioner Nurse Prescribers may not prescribe unlicensed medicines.
Mixing of Medicines
“Mixing” has been defined by the MHRA as “the combination of two or more medicinal products together
for the purposes of administering them to meet the needs of a particular patient”. By mixing two licensed
drugs an unlicensed preparation is created and the prescriber assumes the same responsibility as they
would when prescribing an unlicensed medicine.
Due to the risks of drug incompatibility and chemical reaction, which may have serious adverse effects,
the mixing of drugs should be avoided unless it is essential to meet the needs of the patient, e.g. in
palliative care where an analgesic and anti-emetic may be mixed and delivered in a low-volume,
continuous, sub-cutaneous infusion.
Nurse and pharmacist independent prescribers are permitted to mix medicines prior to administration and
provide written directions for others to do so. They must ensure that the medicines are compatible for
mixing before prescribing, mixing, administering or providing directions for others.
Supplementary prescribers are permitted to mix medicines prior to administration and provide written
directions for others to do so, only when it is safe to do so and the preparation forms part of the clinical
management plan for an individual patient.
Community Practitioner Nurse Prescribers may not provide written directions for others to mix medicines,
but may mix medicines on the direction of an independent / supplementary prescriber.
Those involved in prescribing or mixing should be competent to do so and take full professional and
clinical responsibility for their actions.
Controlled Drugs (CDs)
Controlled drugs are those which are listed in one of the schedules of the Misuse of Drugs Act, 1971. The
Misuse of Drugs Regulations stipulates the prescribing, storage, documentation, etc. requirements
associated with each of the schedules.
Supplementary prescribers may prescribe schedule 2, 3, 4 and 5 controlled drugs as long as they are
detailed in the clinical management plan.
Prescribers must ensure that they are familiar with the various drug schedules, details of which can be
found in the British National Formulary (with the exception of schedule 5). All NMPs are also required to
familiarise themselves with, and adhere to, the Trust’s Controlled Drug Policy.
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Adapted from the University Hospital of South Manchester Community Services NMP policy v1.0 2013
DOCUMENTATION
All prescribing must be carried out using FP10 stationery, which is only available after registration as a
prescriber with the organisation and with Prescription Services.
The prescription form must be completed in full, irrespective of whether it is computer generated or
handwritten. Non-medical prescribers’ designation (e.g. Community Practitioner Nurse Prescriber, Nurse
Independent Prescriber, Podiatrist Supplementary Prescriber, etc.) must be indicated on the prescription;
this would usually be pre-printed or automatically printed by computer software, but must be verified by
the prescriber before the prescription is handed to the patient.
The non-medical prescriber must keep a record of the serial numbers of FP10 prescriptions received and
used to facilitate reporting of missing prescription forms should the need arise.
Details of prescribing must be communicated to the patient’s GP and recorded in the patient’s record. It
may also be prudent to record details for self-audit of prescribing practice.
Community Services FP10 Prescriptions are the property of the organisation who hold the prescribing
budget. It is the responsibility of the prescriber to ensure the security of prescription forms at all times.
Lost or stolen FP10 prescription forms must be reported as such immediately according to the process
detailed in appendix D.
Patient record
Details of assessments, diagnoses, treatments, prescriptions and monitoring / follow-up must be recorded
in the patient record.
All records must be comprehensive, contemporaneous and made according to professional standards.
Copies of clinical management plans must be filed in the patient record.
INCIDENTS AND ADVERSE DRUG REACTIONS
All incidents (deviation from agreed process) and suspected adverse drug reactions must be reported
according to the Trust incident reporting policy.
Adverse drug reactions should also be reported according to the Medicines Policy, i.e. to the Yellow Card
Scheme (where appropriate), to the GP, and recorded in the patient record.
CONTINUING PROFESSIONAL DEVELOPMENT (CPD)
All practitioners are required to undertake CPD in line with the standards laid down by their professional
regulator. New NMC regulations for revalidation of nurses and midwives will be introduced in April 2016.
Non-medical prescribers must ensure that this encompasses the legal, ethical and technical aspects of
their prescribing practice as well as the clinical ones.
It is the responsibility of non-medical prescribers to ensure that they maintain their knowledge and skills to
prescribe by accessing relevant literature, e-learning programmes, professional meetings, clinical
supervision and peer review.
Non-medical prescribers may wish to attend the Non-Medical Prescribing Forum, details of which can be
obtained from the CCG NMP Lead.
Page 6 of 11
Adapted from the University Hospital of South Manchester Community Services NMP policy v1.0 2013
APPENDICIES
APPENDIX A
Equality Impact Assessment of Non-Medical Prescribing Policy
1.
2.
3.
Does the policy/guidance affect one group less or more Yes/N
Comments
favourably than another on the basis of:
o
Race
No
Ethnic origins (including gypsies and travellers)
No
Nationality
No
Gender
No
Culture
No
Religion or belief
No
Sexual orientation including lesbian, gay, bisexual and
transgender people
No
Age
No
Disability
No
Is there any evidence that some groups are affected
differently?
If you have identified potential discrimination, are any
exceptions valid, legal and/or justifiable?
No
N/A
4. Is the impact of the policy/guidance likely to be negative?
No
5.
If so can the impact be avoided?
N/A
6.
What alternatives are there to achieving the
policy/guidance without the impact?
N/A
7.
Can we reduce the impact by taking different action?
N/A
Page 7 of 11
Adapted from the University Hospital of South Manchester Community Services NMP policy v1.0 2013
APPENDIX B
Clinical Management Plan (CMP) Template
Patient Details
Full name:
NHS number:
Independent prescriber (IP):
Allergies/sensitivities:
Date of birth:
Supplementary prescriber(s):
Condition to be treated:
Aim of treatment:
Relevant medical history:
Medication history:
Medication that may be prescribed by the supplementary prescriber(s)
Preparation
Indication
Dose schedule
Specific indications for
referral back to IP
Guidelines or protocols supporting CMP
Frequency of review and monitoring with IP:
Agreed by IP (sign):
Agreed by SP(s) (sign):
Date:
Date:
Date agreed with patient:
Page 8 of 11
Adapted from the University Hospital of South Manchester Community Services NMP policy v1.0 2013
APPENDIX C
Advice on Security of Prescription Forms
Adapted from Security of prescription forms guidance issued by the NHS Security Management Service.
Prescriptions are the property of organisation holding the prescribing budget. It is the responsibility of the
prescriber to ensure the security of prescription forms at all times.
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Managers must ensure that a process is in place to record relevant details of prescription forms in
a stock control system, including the following: date when new prescriptions were ordered date of
receipt name of the receiving person quantity of prescriptions received serial numbers of
prescription received which prescription forms have been issued to each prescriber where the
prescription forms are stored
Records of serial numbers of prescription forms received and issued should be retained for at
least three years.
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It is advisable to hold minimal stocks of prescription stationery.
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Prescription forms (including any completed prescriptions) must be stored in a locked cupboard /
drawer within a locked room when not in use.
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Blank prescriptions must never be pre-signed.
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Prescribers should keep a record of the serial numbers of prescription forms for reference in the
event of theft / loss. The first and last serial numbers of prescription pads should be recorded. It is
also good practice to record the serial number of the first remaining prescription form in an in-use
pad at the end of the working day. This will help to identify any prescriptions lost or stolen
overnight.
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Patients, temporary staff and visitors must never be left alone with prescription forms or allowed
into secure areas where forms are stored.
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All unused forms should be returned to stock at the end of the session or day. They must not, for
example, be left in patients’ notes.
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Service stamps must be kept in a secure location separate from prescription forms. The stamp
pads must be secured to the same standard as prescription forms.
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Services must keep a record of prescription forms / pads issued to locums.
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If an error is made on a prescription, best practice is for the prescriber to do one of the following:
o
o
put a line through the script and write ‘spoiled’ on the form
cross out the error, initial and date the error, then write the correct information
Page 9 of 11
Adapted from the University Hospital of South Manchester Community Services NMP policy v1.0 2013
o
destroy the form and start writing a new prescription.
When making home visits or visits to care homes, prescribers must ensure that prescription pads
are not left in view in a vehicle; they should be stored in a locked compartment, such as a car
boot, in an unidentifiable lockable carrying case. Prescribers on home visits should also, before
leaving their base, record the serial numbers of any prescription forms / pads they are carrying.
Only a small number of prescription forms should be taken on home visits to minimise the potential
loss. Prescription pads must not be left in vehicles overnight.
Supplies of blank or signed prescription forms must not be left at care homes for prescriber visits.
Each prescriber should carry his / her own supply of prescription forms as a matter of course when
making care home visits.
All staff members who have access to computerised prescribing systems must have an individual
password. They must not share the passwords with anyone and systems should prompt users to
change passwords on a regular basis.
Computer systems should have a screensaver facility so that access can be denied or to prevent
details from being read from the screen when the user is going to be away from the desk. The
screensaver should be controlled by a password that is known only to the user and the computer
only able to be unlocked when the password is re-entered. This may be the same as the user’s
‘log on’ password.
In the following circumstances, all unused or obsolete prescription forms must be destroyed in a
secure manner, and computer software amended so that no further prescriptions can be issued
bearing the details of the prescriber in question:
 if a prescriber leaves the organisation, e.g. resigns or dies
 sickness or absence of more than 4 weeks
 prior to commencement of maternity leave
 when changing to a new role within the organisation that does not include prescribing.
An appropriate person must securely destroy the prescription forms, e.g. by shredding before
placing into confidential waste. The person who destroys the forms must make a record of the
serial numbers of the forms destroyed and another member of staff should witness the destruction.
For further information, including an example of a suggested prescription form register, see
Security of prescription forms guidance issued by the NHS Security Management Service, which
can be accessed via the following link
Alternatively, contact the Community Services Non-Medical Prescribing Lead.
Page 10 of 11
Adapted from the University Hospital of South Manchester Community Services NMP policy v1.0 2013
APPENDIX D
Actions to be taken if Prescriptions are Missing / Stolen
Adapted from Security of Prescription Forms guidance issued by the NHS Security Management Service
(NHS SMS), October 2009
In the event of prescription(s) being lost or stolen the following actions should be taken:
1. Report the incident to Essex Police on101
2. Inform the Medicines Management Team (based at Harcourt House) in order to alert all
pharmacies in the area and adjacent NHS organisations. Tel: (01702) 314311.
3. Inform your line manager and the Non-Medical Prescribing Lead (Chief Nurse, based at Pearl
House, 12 Castle Rd, Rayleigh). Tel: (01268) 464508.
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The following information is required (if known):
Date and time of loss/theft
Date and time of reporting loss/theft
Place where loss/theft occurred
Type of prescription stationery
Serial numbers
Quantity.
On being informed of the loss of FP10 prescriptions the NMP Lead should:
 Reinforce the actions to be taken by the person reporting the incident including ensuring that
the matter is recorded as a security incident according to the organisation’s incident reporting
policy.
 Liaise with senior Medicines Management staff within Castle Point & Rochford CCG.
 Inform the organisation’s Local Security Management Specialist (LSMS).
 Inform that organisations’ Accountable Officer for controlled drugs.
The Supplies Officer will inform the prescriber of any action to take, e.g. writing and signing prescription
forms in a particular colour for a specific period of time.
Please note: Staff may report any concerns about fraud to the confidential NHS Fraud and
Corruption Reporting Line on 0800 028 4060.
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Adapted from the University Hospital of South Manchester Community Services NMP policy v1.0 2013