Introduction
The purpose of this policy is to define the standards for Clinicians and Non-Clinicians working in BrisDoc services in the prescribing, administering, dispensing, ordering, and storage of medicines to ensure compliance with best practice and legal requirements.
The aim of a standardised approach is to eliminate error, the risk of harm to patients, and protect staff.
Definitions
Any substance or combination of substances presented for treating or preventing disease whose primary mode of action is pharmacological, metabolic, or immunological. Any substance or combination of substances which may be administered with a view to making a medical diagnosis or restoring, correcting, or modifying physiological or psychological functions.
A Controlled Drug (CD) is a drug identified by the Misuse of Drugs Act 1971 and related Regulations as having potential for diversion and misuse. The Regulations divide the CDs into five Schedules with differing levels of control, depending on therapeutic benefit balanced against harm when misused. BrisDoc do not differentiate the level of control in each schedule of controlled drug, all controlled drugs are managed with schedule two requirements.
To authorise in writing the supply and/or administration of a medicine.
A registered doctor who may prescribe any licensed medicine for any medical condition according to the authorised formulary for their profession, including Controlled Drugs.
Independent Prescribers
Nurse and AHP Independent Prescribers are registered clinicians who are entered on the relevant parts of their professional Register and may prescribe any licensed medicine for any medical condition according to the authorised formulary for their profession, including Controlled Drugs.
An Independent Prescriber must work within their own level of professional competence and expertise.
Supplementary Prescribing is defined as a voluntary partnership between an independent prescriber (doctor or dentist) and a supplementary prescriber to implement and agreed patient-specific Clinical Management Plan with the agreement of the patient. The key principles of supplementary prescribing emphasise the importance of communication between the prescribing partners (the patient is treated as a partner in their care) and the need for access to shared patient records.
A pharmacist is currently trained to dispense medication but they can also with further qualifications, prescribe medication.
Prescription Form
Prescription Forms (NHS England) FP10 are secure prescription forms, serially numbered with anti-counterfeiting and anti-forgery features. Prescriptions are controlled stationery therefore must be stored securely, fully accounted for and reported if missing. Prescriptions are ordered via a secure ordering system and distributed free. The range of forms is listed on the Department of Health (DH) and NHS Business Services Authority (NHSBSA) websites. Please note there are no prescription forms currently held for home visiting/outreach at the homeless health service (HHS) as it is deemed too high risk with this patient population.
To give a medicine by introduction into the body (e.g., orally, rectally, by inhalation or by injection) or by external application (e.g., a cream, ointment, patch).
Supply
To provide a clinically appropriate medicine for a patient for self-administration or administration by another person.
A specific written instruction for the supply or administration of named medicines in an identified clinical situation in the absence of a written prescription.
Responsibilities
Medical Director
Responsible for the safe and secure handling of medicines and Accountable Officer for controlled drugs. This is delegated to the Deputy Medical Director for the respective service line in their absence.
Lead Clinicians (GP, Nurse, Allied Health Professionals [AHPs] and Pharmacists)
Lead clinicians (medical and non-medical), including the Clinical Guardian team, in each service are responsible for prescribing practice and supervision of all prescribers. They will ensure robust prescribing policy and procedure is followed and developed in their service as team leaders. There is a governance structure through which all leads will be accountable for the appropriate ordering, storing and stock management of medicines held in BrisDoc premises. Nominated representatives from this group will attend and liaise with the respective medicines Management Groups as required.
Facilities Manager and Practice Managers
Practice Managers, in practices and the Facilities Team oversees the management of medicines, stock control and prescriptions pads. They will action appropriate drug alerts, received by the Governance team from the MHRA, arranging for stock to be checked, withdrawn, and replaced as appropriate across services.
Lead Pharmacist and Pharmacy Support
The Lead Pharmacist will provide support for audit, advice on best practice, monitoring prescriptions, provision of reports on medicines used and their cost, medicines supplier and PGD sign off.
Additional Pharmacist support with regards to Medicines management and prescribing data is provided by NHS Bristol, North Somerset, South Gloucestershire (BNSSG) Integrated Care Board (ICB).
Facilities Team
The facilities team is responsible for checking, monitoring, and replenishing medicines stocks in all IUC Treatment Centres and cars.
Specific tasks include:
- Assessing medicines stock against minimum levels, determine what replacements are required
- Check expiry dates, rotate stock, tidy medicines stocks
- Collect medicines (which will always be delivered to Osprey Court) from Osprey and store at relevant Treatment Centre
- Maintain records of stock levels
- Reconcile prescriptions for medicines supplied by clinicians against stock lists
- Submit records to the Facilities Team for review and action
- Log a learning event if stocks do not reconcile and escalate to line management
- Managing the withdrawal and replenishment of stock recalled through a drug alert
Any discrepancies will be alerted to the Facilities Team with regards to any potential over usage of a medicine for review and investigation. All drug orders will be kept for a period of 2 years to ensure any trend analysis can be noted.
Please refer to Facilities Team Weekly Medication Processes SOP.
Practice Services
Delegated authority will be given by the Lead GP to the lead nurse in each service who will be responsible for the monitoring, ordering and storage of medication. They will be supported by other members of their team together with the lead Pharmacist. Any concerns will be reported via the learning event process and relevant data/reports will be reviewed at the medicines management committee meetings. Practice services do not accept any patient return of medications.
Medicines Management Group
Please see Medicines Management Group Terms of Reference.
All Clinicians
All clinicians, whether prescribers or not, must comply with legislation, their professional body requirements, and guidelines, and BrisDoc medicines policies and procedures. Clinicians are responsible for their own prescribing practice and accountable for their actions.
Prescriptions will only ever be in accordance with the clinician’s license to prescribe, and will be within BNF and local formulary guidelines, or the departure therefrom will be clearly documented.