Policy responses and statements

Name of organisation:

National Clinical Dataset Development Programme

Name of policy document:

Generic Medication Data Standards: Consultation Document

Deadline for response:

30 June 2006

Background: Feedback was sought on the consultation document on 'National Clinical Data Standards for Medication'. The Medication Standards will support the recording and communication of patient medication and device details. It is important to emphasise that they have not been developed to facilitate electronic prescribing.

Feedback is essential since these data items and definitions will be those which will be used in any Electronic Patient Record in Scotland. Systems which adhere to these data standards will be able to communicate with each other and share information (for instance between primary and secondary care and between hospitals) - this is vital to optimise the care for our patients. This is your opportunity to ensure that they are fit for purpose.

National data standards:

• support direct patient care, being informed by prevailing best practice guidance
• support secondary data requirements where possible including data to support clinical governance
• are freely and widely available through publication on the Health & Social Care Data Dictionary
• incorporate agreed national clinical definitions and implement national terminology

These data standards are for consultation only and that existing systems should not be modified to meet the specifications within this document. Once agreed, the standards will be published through the Health and Social Care Data Dictionary.

COMMENTS ON
NATIONAL CLINICAL DATASET DEVELOPMENT PROGRAMME
GENERIC MEDICATION DATA STANDARDS: CONSULTATION DOCUMENT

The Royal College of Physicians of Edinburgh is pleased to respond to this consultation from the National Clinical Dataset Development Programme, and is supportive of attempts to provide meaningful data on prescribing activity.  We believe this will eventually lead to improved monitoring of the effectiveness and safety of drug use in NHS Scotland. 

The title of the consultation document is rather unfortunate.  “Generic medications” has a specific meaning within clinical practice and we believe that the document would be more properly entitled “Generic Data Standards for Medication” ie it is the standards that are generic, and not the medications.

Our further comments are referenced to the pages or sections of the consultation document.

Page 8:  Medications and Devices Record Table: Complementary & Alternative Medicine or Therapy

Whilst recognising that complementary medications may need to be included at some stage, the College is concerned that these really defy definition, and that there are no recognised standards for these treatments.  Herbal medicines are covered in part by the Medicines Act, some are licensed in the UK and the Commission on Human Medicine has responsibility for those, others are completely unlicensed.  A third group are now covered by European Medicines legislation, and monitoring of these fall to the new Herbal Medicines Advisory Committee.  Similarly, homeopathic products are monitored by the Advisory Board on the Registration of Homeopathic Products.  It should therefore be possible to get names and license information for some of these medicines, but the whole picture is very confusing.  The College understands the wish to include all types of medication and products given to patients but this may be a step too far.

Section 1.1:  Medication or Device Name

Under ‘common name’, this should read ‘non-proprietary drug name’.  The College supports the use of generic drug names, but recognises that there may be situations in which the manufacturer’s trade name is important, particularly where the preparation used is of particular importance ie anticonvulsants.  There should therefore also be a field for recording proprietary names.

Section 1.5:  Duration

Planned duration of therapy may not be known at the time of initiation, so an option for “not known” might be required here.

Section 1.6:  Medication Dosage

What is the rationale for a single field?  There are quite clearly separate data items for form, dosage, frequency and these should be specified separately similar in the way to route of administration being specified separately. 

Section 1.7:  Route of Administration

Routes of administration different from topical, which are not included in the current table, include transdermal, buccal and sublingual.  Rectal and nasal also require to be considered.

Section 2:  Medication Concordance

Our Fellows were very concerned about the definitions and use of language in this section.  Section 2.1 actually includes two separate definitions of medication concordance.  The second of those ie “in accordance with the agreement between the patient and the health care professional” is a fair definition of concordance.  The first part of their definition is the meaning of the now rather old-fashioned concept of compliance.  If a single word is to be used to encompass both these concepts it would be better to use the word “adherence”.  The titles of this and all sub-sections have the same problem.  We would recommend that the titles of this section be amended.

Copies of this response are available from:

Lesley Lockhart,
Royal College of Physicians of Edinburgh,
9 Queen Street,
Edinburgh,
EH2 1JQ.

Tel: 0131 225 7324    ext 608
Fax: 0131 220 3939

[29 June 2006]