Response of the National Pharmaceutical Association to Consultation MLX 320
Thank you for giving the National Pharmaceutical Association (NPA) the opportunity to comment on consultation letter MLX 320 on options for the future of independent prescribing by Extended Formulary nurse prescribers.
The NPA represents the interests of community pharmacies. We have, in voluntary membership, around 11,000 community pharmacies, which comprises the majority of the 12,000 pharmacies in the UK. The NPA provides a representative voice for its members as well as a range of services to help them with both commercial and professional aspects of running their businesses.
Definition of independent prescribers
We support the proposed definition of independent prescribers and agree that this definition should apply to all independent prescribers including nurses and pharmacists.
Options for the future development of nurse prescribing
The NPA supports Option D: prescribing for any medical condition from a full formulary. We believe that this will lead to better patient care as patients will have improved access to the medicines they need. The NPA believes that independent nurse prescribers will be highly skilled healthcare professionals and should have access to prescribe any medicine in order to treat patients within their sphere of competency.
However, in order to prescribe in this way we believe that independent nurse prescribers will require comprehensive and appropriate training. There must be robust training in medication review and competency in medication review must be demonstrated before nurses are eligible to prescribe. In addition, competency in their particular clinical field should be demonstrated before the nurse is able to independently prescribe
Prescriptions should be clearly annotated so that it is clear to community pharmacists who are presented with prescriptions for dispensing which level of nurse prescriber has prescribed the medication.
Controlled Drugs
We agree that independent nurse prescribers should be able to prescribe controlled drugs as part of their role as supplementary prescribers. In our opinion it is not appropriate for independent nurse prescribers to be restricted in their prescribing of controlled drugs. For example independent nurse prescribers working in the field of palliative care should be able to prescribe appropriate controlled drugs necessary for the treatment of their patient without undue delay which may lead to increased patient suffering.
"Off label" or "Off licence" prescribing
The consultation does not mention the issue of "off label" or "off licence" prescribing for independent nurse prescribers. However there are certain circumstances, for example in the field of palliative care, where "off label" prescribing would be safe and effective practice. We would like confirmation that independent nurse prescribers will be eligible to prescribe "off label" medicines in appropriate circumstances.
Summary
The NPA supports the proposal for independent prescribing by extended formulary nurse prescribers however we have concerns about the legal and liability issues involved.
Independent nurse prescribers should only be able to prescribe within their sphere of competency and we envisage that independent nurse prescribers will normally only prescribe within their chosen clinical area. Nurse prescribers and their employers must be fully aware of the legal and liability issues involved in prescribing.
Monitoring of nurse prescribing should be carried out at PCO level. It is not appropriate for community pharmacists to be expected to monitor or check the eligibility of an independent nurse prescriber when presented with a prescription for dispensing as this will cause unnecessary delay for the patient in receiving treatment.
25 May 2005
