Policy responses and statements

Name of organisation:

Home Office Drug Legislation Section

Name of policy document:

Independent Prescribing of Controlled Drugs by Nurse and Pharmacist Independent Prescribers

Deadline for response:

15 June 2007

Note: This consultation letter sought views on the proposals to expand the range of Controlled Drugs that can be prescribed independently by Nurse Independent Prescribers and to enable Pharmacist Independent Prescribers to independently prescribe Controlled Drugs. It also seeks views on whether nurse and pharmacist prescribers should be allowed to prescribe specific Schedule 2 drugs to addicts for the management of their addiction.

This consultation letter was drawn up by the Home Office in consultation with the Department of Health, as well as the Advisory Council on the Misuse of Drugs (ACMD).

Nurse Independent Prescribers are currently able to prescribe 12 Controlled Drugs independently, including diamorphine and morphine, solely for specified medical conditions.

Pharmacist Independent Prescribers are unable to prescribe any Controlled Drugs independently (though community pharmacists can sell Schedule 5 Controlled Drugs from a pharmacy).

Both nurse and pharmacist supplementary prescribers can prescribe Controlled Drugs under a Clinical Management Plan for a patient in partnership with a doctor.

COMMENTS ON
HOME OFFICE: DRUG LEGISLATION SECTION
INDEPENDENT PRESCRIBING OF CONTROLLED DRUGS BY NURSE AND PHARMACIST INDEPENDENT PRESCRIBERS

The Royal College of Physicians of Edinburgh is pleased to respond to the Home Office on its consultation on Independent Prescribing of Controlled Drugs by Nurse and Pharmacist Independent Prescribers.

Subject to appropriate governance, monitoring and training arrangements being in place, the Government’s position appears to be that prescribing by qualified nurse and pharmacist prescribers should be considered in much the same way as prescribing by doctors.  This process advanced significantly in May 2006 after consultation.  The proposals in this latest consultation document seek to bring current arrangements regarding controlled drugs further into line with this view.

The proposed amendment noted in Para 18 for the expansion of prescribing controlled drugs by nurses and pharmacists is a theoretically and operationally logical extension of the decisions on non-medical prescribing made in 2006.  Broadly, the College supports the proposal, subject to some reservations noted below.  The alternatives appear to be less satisfactory.  Option C did find some support, but there was also concern that there was a lack of clarity and simplicity with this proposal.

Without reopening the debate in the previous consultation in 2006 when it was noted that medical organisations had more reservations, it would be useful to have some evidence that the changes already in place are working.

The key principles adopted by the CHM and ACMD underpinning the expansion of non-medical prescribing and outlined in Paragraph 16 are important, and some of these merit comment.  The document as it stands misses an opportunity to explain how these issues are addressed.

• Nurse and Pharmacist Independent Prescribers must prescribe within their competence/specialty.  It would be useful to clarify, especially in the case of Pharmacists, what specialist competence means and how specialism is regulated within that profession.

• Training for Nurse and Pharmacist Independent prescribers must be monitored, validated and quality assured, and include, as it does, the legal requirements of prescribing Controlled Drugs.  It would be helpful, not least to promote development in this area, if these processes were more widely known.  Many contributing to the College view were not familiar with these.

• Clinical governance arrangements must be fully in place for Nurse and Pharmacist Independent Prescribers.  Again, these processes are not widely known.  In an increasingly team based approach to care, lines of responsibility can become confused.

• Communication between prescribers is vital, and all prescribers must have access to the appropriate part of the patient's medical records.  In an increasingly complex medical environment, the term ‘independent’ is in some respects unfortunate.  Whilst it correctly implies responsibility as identified above, it is important that it does not imply isolation from information, advice, supervision and recognition of limitation

The College would agree that there is no clear justification at present for amendments to allow non-medical prescribers to prescribe diamorphine (cocaine or dipipanone) for addicts for the management of addiction under Home Office licence.

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

[8 June 2007]