Policy responses and statements
- Name of organisation:
- General Medical Council
- Name of policy document:
- Good practice in prescribing medicines
- Deadline for response:
- 8 October 2010
Background: The GMC has requested the College's help
in reviewing its guidance for doctors on good prescribing practice,
including remote consultations, prescribing off-label and related issues.
The GMC's guidance 'Good practice in prescribing medcines' (2008) gives
background information.
Questions about prescribing are frequently raised by doctors contacting
the GMC for advice, and it is a topic that features frequently in fitness
to practise investigations. The GMC is keen to review the scope of
its guidance in this area to ensure that it is up-to-date and relevant
to the concerns of doctors, patients, employers and other regulators.
The College is invited to contribute to this initial review to identify
issues that should be covered in any revised publication and to comment
on the relevance of (and possibly suggest answers to) a number of issues
which the GMC has already identified.
COMMENTS ON
GENERAL MEDICAL
COUNCIL
GOOD
PRACTICE IN PRESCRIBING MEDICINES
The Royal College of Physicians of Edinburgh is pleased to respond
to this review of the 2008 guidance on prescribing medicines. The
current GMC document is already comprehensive and covers many of the
key issues. However, the following issues may merit some attention
in an updated version:
Prescribing appropriate drugs in partnership with patients -
paragraph 5 of the guidance identifies the ideal circumstances and
should recognise that these responsibilities fall to a healthcare team
(doctor, pharmacist, nurse) in many NHS circumstances and cannot always
be the sole responsibility of the doctor. Equally, the responsibility
given to doctors to ensure patients have sufficient knowledge of the
effects of their medication (including serious side effects) is a challenge
in terms of delivering care in partnership with patients, and the guidance
should be pragmatic and retain an emphasis on judgment.
Prescribing controlled drugs - particularly those
which may potentially cause addiction could perhaps be emphasized as
a particular problem. This particularly relates to the doses
to be used, maximal advised doses (eg for methadone) and management
of drug withdrawal.
Unlicensed and non-NHS prescribing - these
are complex issues, particularly as the NHS will focus increasingly
on drugs that are specifically approved and patients may have particular
preferences in terms of previous history or having read literature
on the internet. A recent example might be taken from co-proxamol,
which remains popular with some patients despite the scientific evidence
to the contrary.
Private sector prescribing - this is an area
where there are particular concerns, such as the use of propofol (the
cause of the death of Michael Jackson) intravenously as a short-acting
sedative or prescribing chelation therapy for patients who do not have
a proper diagnosis. This might be best addressed by the GMC guidance
strongly advising that people who do not have appropriate CCTs or postgraduate
specialist training that they should not be prescribing drugs outwith
their professional competency.
Prescribing for children - many drugs given to children
are, of course, "unlicensed" and the guidance already comments
on the resulting confusion. Clear guidance on the difference
between a correct indication and a correct licence may be needed.
Prescribing by provisionally registered doctors -
many of the well publicised difficulties in prescribing have related
to doctors with provisional registration. While the GMC requirement
that doctors should prescribe within the local supervisory structures
is appropriate, the reality is that this can be very poorly set out
for this group of doctors and the guidance could be more specific on
the supervisory arrangements for provisionally registered doctors.
Other prescribers - the GMC is clearly targeting
doctors with this guidance but, as other groups are now able to prescribe
quite widely, this should be acknowledged in the GMC guidance
for doctors to ensure that any supervising responsibilities for nurse
or AHP prescribers is given due attention. The GMC may wish
to explore the regulatory advice given to other prescribing professionals
and cross reference within the updated GMC guidance for doctors.
Internet/remote prescribing – the definition
of “dialogue” is unclear. Is it sufficient for a
patient to complete a questionnaire (para 41b), and who would be accountable
for difficulties arising from withheld information via in these circumstances?
Finally, as many prescribing problems occur at the interface between
primary and secondary healthcare with limited exchange of prescribing
information, it may be helpful to emphasise the importance of this
risk within the guidance.
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
[7 October 2010]
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