When did the new prescribing standards come into effect?
We began approving all prescribing programmes against the new Standards for prescribing programmes from 28 January 2019.
Can I use my V300 nurse/midwife independent prescriber qualification to prescribe whilst working as a physician associate?
The physician associate role is not a regulated profession, but other health and care professionals, such as registered nurses or midwives, can work in that role. Physician associates in the UK are unable to prescribe medication by virtue of working as a physician associates.
However, a registered nurse or midwife with prescribing rights working as a physician associate is able to prescribe medication by relying on their nursing or midwifery knowledge, skills or experience in that role. In this case, you would be working within your scope of practice as a registered nurse or midwife and would therefore be subject to regulation by us.
You would need to maintain your nursing or midwifery registration and continue to meet our requirements for registration for this to apply.
There is currently only a voluntary register for the physician associate role. If this role were to become regulated on a statutory basis in the future, your work may then fall outside the scope of your registered nursing or midwifery practice, and we will review this position.
What do I need to consider as a nurse, midwife or nursing associate when medicines are prescribed remotely?
We don’t issue guidance for specific areas of practice or for individual named medicines. However, the information set out below needs to be considered by any nurse, midwife or nursing associate working in any setting.
This includes those working in a cosmetic or aesthetic practice setting.
If you’re a prescriber
If you hold prescribing qualifications, you must prescribe in line with the requirements of the Code and your individual scope of practice. This means you must prescribe in line with best available evidence and the requirements of all relevant legislation, as well as any policies, standards and guidance that underpin the Code.
This applies to all forms of prescribing, including remote prescribing; and to all medicinal products, including non-surgical medicinal products being used for cosmetic and aesthetic purposes, such as Botox.
The Code states at section 18.1 that those suitably qualified must only prescribe, advise on, or provide medicines or treatment, including repeat prescriptions if you have enough knowledge of that person’s health and are satisfied that the medicines or treatment serve that person’s health needs.
In March 2018, our Council agreed to adopt the ‘Royal Pharmaceutical Society (RPS) Competency Framework for all Prescribers’ as our standards of competency for prescribing practice. Nurse and midwife prescribers should use the framework as the benchmark for safe and effective prescribing practice.
The RPS competency framework sets out a list of steps a prescriber must undertake prior to issuing a prescription. This includes:
- taking an appropriate history (competency 1.1),
- undertaking an appropriate clinical assessment (competency 1.2), and
- having a full understanding of the conditions to be treated by way of prescribing medication (competency 1.6).
It also states that:
- prescribers should identify the potential risks associated with prescribing remotely, and take steps to minimise them (competency 7.3); and
- minimise risk to patients by using processes that support safe prescribing in areas of high risk (competency 7.4).
We would expect all nurse and midwife prescribers to adhere to the RPS competency framework as the standards for safe and effective practice in prescribing in order to ensure patient safety and public protection.
All prescribers must take individual responsibility for their prescribing decisions and should recognise that there are certain areas of practice where remote prescribing is unlikely to be suitable, for example when prescribing medicines likely to be subject to misuse or abuse, or injectable cosmetic treatments.
We recommend that it is good practice for face to face consultations to take place before prescriptions are issued in the cosmetic context.
If you’re involved in administration of medicines
If you’re administering medicines which have been prescribed by another person (including when the prescribing has been done remotely), you have a responsibility under the Code to ensure that you’re satisfied that the RPS competency framework has been followed and patient safety is not at risk.
This means you should say no if asked to supply or administer any medicinal product if you have concerns that the prescribing has not been carried out appropriately and in line with the requirements of the Code, the Royal Pharmaceutical Society (RPS) Competency Framework or other applicable standards and guidance.
If you feel that patient or public safety is being put at risk or if you’re being asked to work outside of the requirements of the Code or any other national standards, you’re empowered under the Code to raise your concerns (see section 16.1 of the Code for more details).
High level principles for good practice in remote consultations and prescribing
In November 2019 healthcare organisations including regulators, royal colleges and faculties, issued a set of principles to help protect patient safety and welfare when accessing potentially-harmful medications online or over the phone.
The jointly-agreed High level principles for good practice in remote consultations and prescribing sets out the good practice expected of healthcare professionals when prescribing medication online.
The ten principles underpinned by existing standards and guidance, include that healthcare professionals are expected to:
- Understand how to identify vulnerable patients and take appropriate steps to protect them
- Carry out clinical assessments and medical record checks to ensure medication is safe and appropriate
- Raise concerns when adequate patient safeguards aren’t in place.
See further information
Read the Code
Read theRoyal Pharmaceutical Society (RPS) Competency Framework
Read our joint statement on meeting regulatory standards during periods of global or national shortage of medicines
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Regarding the question about the new prescribing standards, the new Standards for prescribing programs came into effect on January 28, 2019 These standards were implemented to ensure that prescribing programs meet the required criteria and provide safe and effective prescribing practices.
As for using a V300 nurse/midwife independent prescriber qualification to prescribe while working as a physician associate, it is important to note that the physician associate role is not a regulated profession. However, registered nurses or midwives can work in that role. Physician associates in the UK are unable to prescribe medication by virtue of working as a physician associate. However, a registered nurse or midwife with prescribing rights working as a physician associate can prescribe medication by relying on their nursing or midwifery knowledge, skills, or experience in that role. In this case, they would be working within their scope of practice as a registered nurse or midwife and would be subject to regulation by the relevant authorities. It is necessary to maintain nursing or midwifery registration and continue to meet the requirements for registration for this to apply. If the physician associate role were to become regulated on a statutory basis in the future, the work of registered nurses or midwives in that role may fall outside the scope of their registered nursing or midwifery practice, and this position would be reviewed .
When it comes to prescribing remotely as a nurse, midwife, or nursing associate, there are certain considerations to keep in mind. The Nursing and Midwifery Council (NMC) does not issue guidance for specific areas of practice or individual named medicines. However, there are general principles that need to be considered by any nurse, midwife, or nursing associate working in any setting, including those working in a cosmetic or aesthetic practice setting. If you hold prescribing qualifications, you must prescribe in line with the requirements of the Code and your individual scope of practice. This means prescribing in line with the best available evidence, relevant legislation, and any policies, standards, and guidance that underpin the Code. The RPS Competency Framework for all Prescribers is adopted as the standards of competency for prescribing practice. Nurse and midwife prescribers should use this framework as the benchmark for safe and effective prescribing practice. It sets out a list of steps a prescriber must undertake before issuing a prescription, including taking an appropriate history, undertaking an appropriate clinical assessment, and having a full understanding of the conditions to be treated by prescribing medication. Prescribers should also identify potential risks associated with remote prescribing and take steps to minimize them. It is important to adhere to the RPS competency framework to ensure patient safety and public protection. Individual responsibility for prescribing decisions is emphasized, and there are certain areas of practice where remote prescribing may not be suitable. Face-to-face consultations are recommended before issuing prescriptions in the cosmetic context. If you are involved in the administration of medicines prescribed by another person, you have a responsibility to ensure that the RPS competency framework has been followed and patient safety is not at risk. If you have concerns about the appropriateness of the prescribing or if patient or public safety is being put at risk, you are empowered to raise your concerns .
In November 2019, healthcare organizations, including regulators, royal colleges, and faculties, issued a set of principles called the High-Level Principles for Good Practice in Remote Consultations and Prescribing. These principles aim to protect patient safety and welfare when accessing potentially harmful medications online or over the phone. The principles include understanding how to identify vulnerable patients and taking appropriate steps to protect them, carrying out clinical assessments and medical record checks to ensure medication is safe and appropriate, and raising concerns when adequate patient safeguards are not in place.
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