NPA comment on the proposals to extend the range of healthcare professionals entitled to supply medicine to patients by way of supplementary prescribing. The NPA represents the interests of community pharmacies. We provide a representative voice for its members as well as a range of services to help them with both the commercial and professional aspects of running their businesses. We have, in voluntary membership, around 11,000 community pharmacies, which comprises the majority of the 12,000 pharmacies in the UK.
The NPA supports the principles behind the proposals outlined in this consultation letter. Extending the range of healthcare professionals entitled to supply medicine by way of supplementary prescribing is likely to have a positive impact on patient care and access to medicines, particularly in the independent healthcare sector.
In our response to MLX 284 on supplementary prescribing, we stated that we believed the competencies needed to become a supplementary prescriber are the same, regardless of the discipline in which that prescriber specialises. The extra underpinning knowledge required and the route to competency attainment will vary between healthcare professionals but we believe the endpoint will be the same.
The professions of podiatry (chiropody), physiotherapy and radiography are regulated by the Health Professions Council which will agree the curriculum for further study for members of these professions to become supplementary prescribers. We do not envisage any patient safety issues. The profession of optometry is also well established and regulated by the General Optical Council. We are sure that the GOC’s work with the National Prescribing Centre (NPC) to produce competencies for prescribing will ensure patient safety.
Members of these professions already have experience of supplying medicines to patients by a number of different routes, for example by retail sale, by signed order (in the case of optometrists) and by patient group directions.
We agree that the POM Order should be amended to allow suitably trained members of the four professions described to practise as supplementary prescribers. We also agree that the NHS Regulations should be amended to allow these additional supplementary prescribers working in the NHS to prescribe medicines.
Last year the NPA commented on MLX 298 regarding the prescribing of unlicensed medicines by supplementary prescribers. We believe that all supplementary prescribers, regardless of professional background, should be able to prescribe unlicensed medicines where it is appropriate and in the patient’s best interests. Patient safety can be assured because the supplementary prescriber is always required to work within a clinical management plan which will set out limits on prescribing. No significant action can be taken outside the plan without prior authorisation by the independent prescriber and it would then be amended appropriately. Thus, the NPA believes there is no need to restrict the range of medicines suitable for supplementary prescribing.
