NHS Dorset Clinical Commissioning Group
Medicines Code Chapter 3:
Policy for Remote Prescribing
Supporting people in Dorset to lead healthier lives
NHS Dorset Clinical Commissioning Group
PREFACE
The Medicines Code is a multi-professional policy document. It contains all CCG wide
policies relating to medicines management. This policy sets out the requirements for remote
prescribing in Dorset CCG.
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NHS Dorset Clinical Commissioning Group
DOCUMENT HISTORY
Document Status:
Current
Developed by: Medicines Team
Policy Number
ID 39, Version 2.0
Date of Policy
February 2015
Next Review Date
January 2017
Name of Originator / Author
K Gough, Head of Medicines Management
Sponsor
Director of Strategy and Quality
Date Policy Approved
March 2015
Approving Committee or Group
Medicines Optimisation Group
Target Audience
All staff within NHS Dorset Clinical Commissioning Group
Distribution
Intranet
CCG Website
Communications bulletin
√
√
√
Version
Date
Comments
By Whom
1.0
July
2013
Hayley Howells
2.0
February
2015
Hayley Howells
Evidence Base References
Date
Refer to references
Associated Documents
Date
Other Medicines Code chapters
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NHS Dorset Clinical Commissioning Group
CONTENTS
1.
INTRODUCTION ............................................................................................................................... 4
2.
SCOPE
3.
GENERAL GUIDANCE ....................................................................................................................... 4
4.
ROYAL PHARMACEUTICAL SOCIETY GUIDANCE .............................................................................. 5
5.
GENERAL MEDICAL COUNCIL (GMC) GUIDANCE ............................................................................ 5
6.
NURSING AND MIDWIFERY (NMC) GUIDANCE ............................................................................... 6
7.
INFORMATION TO BE INCLUDED ON THE REMOTE PRESCRIPTION ............................................... 7
8.
OTHER CONSIDERATIONS ............................................................................................................... 7
9.
DUTIES/RESPONSIBILITES AND ACCOUNTABILITY .......................................................................... 8
..................................................................................................................................... 4
10. ROLES AND RESPONSIBILITIES OF THE SENIOR MANAGEMENT ..................................................... 8
11. COMMITTEE WITH OVERARCHING RESPONSIBILITY FOR SUBJECT ................................................ 8
12. INTERNAL COMMUNICATION ......................................................................................................... 8
13. TRAINING AND CONTINUING PROFESSIONAL DEVELOPMENT....................................................... 9
14. PROCESS FOR COMPLETING RISK ASSESSMENTS IF APPLICABLE ................................................... 9
15. MONITORING COMPLIANCE WITH THE PROCEDURAL DOCUMENT............................................... 9
16. REFERENCES .................................................................................................................................... 9
APPENDIX 1
FAXED / EMAILED REMOTE PRESCRIPTION FORM.................................................... 10
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1.
INTRODUCTION
1.1.
This chapter outlines the policy for remote prescribing by email and fax.
1.2.
Remote prescribing is discouraged, however it is recognised that because of the
geographical site and rurality of NHS Dorset Clinical Commissioning Group it is
necessary to support the facility of faxing and emailing prescriptions by medical
staff in circumstances where a delay in provision of a prescription would be
detrimental to patient care.
1.3.
At this current time, text messaging is not an option and should not be used, even if
via NHS net.
1.4.
This document is underpinned by, and should be read in conjunction with, the
documents listed in the references.
2.
SCOPE
2.1.
This policy applies to all staff throughout NHS Dorset Clinical Commissioning Group,
particularly to all prescribing and dispensing staff.
2.2.
The use of this policy should not be routine practice. It is intended for exceptional
circumstances only.
3.
GENERAL GUIDANCE
3.1.
From time to time it may be appropriate to use a non face-to-face medium to
prescribe medicines and treatment for patients. Such situations may occur where:



3.2.
The prescriber has responsibility for the care of the patient
The prescriber is deputising for another doctor who is responsible for the
continuing care of a patient
The prescriber has prior knowledge and understanding of the patient's
condition/s and medical history and has authority to access the patient's
records.
The remote prescriber must ensure they have adequate information on which to
base their decision to prescribe, sufficient to:




Establish the patient's current medical conditions and history and
concurrent or recent use of other medications including non-prescription
medicines;
Carry out an adequate assessment of the patient's condition;
Identify the likely cause of the patient's condition;
Ensure that there is sufficient justification to prescribe the
medicines/treatment proposed;
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
3.3.
Ensure that the treatment and/or medicine/s are not contra-indicated for
the patient.
If the prescriber is not currently providing continuing care for the patient, does not
have access to the patient's medical records, or is not deputising for another doctor,
they must follow the advice above and, additionally:





Give an explanation to the patient of the processes involved in remote
consultations and give their name to the patient;
Ensure that they have sufficient information about the patient to ensure
they are prescribing safely;
Make appropriate arrangements to follow the progress of the patient;
Monitor the effectiveness of the treatment and/or review the diagnosis;
Inform the patient's general practitioner that remote prescribing has
occurred.
3.4.
Where all these conditions cannot be satisfied remote prescribing should not occur,
and it will be necessary to carry out a full assessment of the patient before any
medicines are prescribed.
4.
ROYAL PHARMACEUTICAL SOCIETY GUIDANCE
4.1.
Medicines Ethics and Practice (Royal Pharmaceutical Society), states that:
“A faxed prescription does not fall within the definition of a legally valid prescription
because it is not written in indelible ink and has not been signed by the appropriate
practitioner. A fax can however, confirm that at the time of receipt, a valid
prescription is in existence”.
5.
GENERAL MEDICAL COUNCIL (GMC) GUIDANCE
5.1.
General Medical Council (GMC) guidance on Remote prescribing via telephone,
video-link or online states:
5.2.
“Before you prescribe for a patient via telephone, video-link or online, you must
satisfy yourself that you can make an adequate assessment, establish a dialogue
and obtain the patient’s consent.
5.3.
You may prescribe only when you have adequate knowledge of the patient’s health,
and are satisfied that the medicines serve the patient’s needs. You must consider:



the limitations of the medium through which you are communicating with the
patient;
the need for physical examination or other assessments; and
whether you have access to the patient’s medical records.
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NHS Dorset Clinical Commissioning Group
5.4.
You must undertake a physical examination of patients before prescribing nonsurgical cosmetic medicinal products such as Botox, Dysport or Vistabel or other
injectable cosmetic medicines. You must not therefore prescribe these medicines by
telephone, video-link, or online.
5.5.
If you are prescribing for a patient in a care or nursing home or hospice, you should
communicate with the patient (or, if that is not practicable, the person caring for
them) to make your assessment and to provide the necessary information and
advice. You should make sure that any instructions, for example for administration
or monitoring the patient’s condition, are understood and send written confirmation
as soon as possible.
5.6.
If the patient has not been referred to you by their general practitioner, you do not
have access to their medical records, and you have not previously provided them
with face-to-face care, you must also:



give your name and, if you are prescribing online, your GMC number;
explain how the remote consultation will work and what to do if they have any
concerns or questions;
follow the [GMC] advice on sharing information with colleagues.
5.7.
You should not collude in the unlawful advertising of prescription only or unlicensed
medicines to the public by prescribing via websites that breach advertising
regulations.
5.8.
If you prescribe for patients who are overseas, you should consider how you or local
healthcare professionals will monitor their condition. You should also have regard to
differences in a product’s licensed name, indications and recommended dosage
regimen. You may also need to consider:



MHRA guidance on import/export requirements and safety of delivery;
whether you will need additional indemnity cover; and
whether you will need to be registered with a regulatory body in the country in
which the prescribed medicines are to be dispensed.
6.
NURSING AND MIDWIFERY (NMC) GUIDANCE
6.1.
The Nursing and Midwifery Council (NMC) guidance on Standards for Medicines
Management contains a statement regarding verbal orders:
“In exceptional circumstances, where medication has been previously prescribed and
the prescriber is unable to issue a new prescription, but where changes to the dose
are considered necessary, the use of information technology (such as fax, text
message or email) may be used but must confirm any change to the original
prescription.”
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NHS Dorset Clinical Commissioning Group
6.2.
Wherever possible, a full assessment of the patient’s condition should be
undertaken before prescribing. Remotely prescribed medication should only be a
short term measure and used only in exceptional circumstances. It is not
appropriate to prescribe remotely in routine care of patients (for example, for
patients who are resident in care homes or community hospitals).
6.3.
Injectable medication should not be prescribed remotely unless, in exceptional
circumstances, it is considered essential in life-threatening situations, for the
management of severe adverse side effects and/or where a service-user is at
significant risk of causing harm to self or others (the use of remote prescribing not
appropriate for long-acting depot injections).
7.
INFORMATION TO BE INCLUDED ON THE REMOTE PRESCRIPTION
7.1.
The remote prescription must provide adequate information, as a minimum:









Patient name in full – first name and surname
Date of birth of the patient
NHS Number (if known)
Known allergies
Drug name
Drug dose, route and frequency
Date of request
Prescribers name prescribing identification number (PIN)
Contact details for the prescriber
7.2.
A template form for remote prescribing by fax is in appendix 1.
8.
OTHER CONSIDERATIONS
8.1.
Any healthcare practitioner that chooses to dispense and/or administer a
medication against a fax or email request, without sight of the original prescription,
must ensure that adequate safeguards exist to ensure the integrity of the original
prescription request is maintained, and that a legal prescription (i.e. signed and
dated FP10 will be in his/her possession within 24 hours).
8.2.
Any doubt as to the content of the fax or email must be clarified with the prescriber
before dispensing or administration of the medication.
8.3.
Under no circumstances can faxes or emails be accepted for medicines listed in
Schedules 2 or 3 of the Misuse of Drugs Regulations 2001. Examples of Schedule 2 or
3 medicines include:
Schedule 2:
Schedule 3:
diamorphine, morphine, methadone, amphetamines,
quinalbarbitone
Buprenorphine (Temgesic®, Subutex®), phenobarbitone,
flunitrazepam, temazepam, midazolam, tramadol, Zopiclone
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NHS Dorset Clinical Commissioning Group
8.4.
Faxed orders and e-mailed prescription requests may only be arranged by a
registered nurse or doctor (not administration or support staff).
8.5.
The prescription must be signed by the prescriber within 24 hours (maximum
72 hours if over a Bank Holiday).
8.6.
The prescriber must be satisfied that the medicine to be supplied is safe for the
patient and check that there are no previous adverse reactions to the drug recorded
in the patient’s medical records.
8.7.
The dispenser may refuse to accept a remote prescription if there is any doubt:


That a legally valid prescription will be provided in a short time
About the content of the prescription (eg poor fax quality)
8.8.
All communication between prescriber and dispenser that has taken place regarding
a remote prescription should be documented.
8.9.
Clear, accurate and legible records of all medicines prescribed remotely must be
made and these records must be kept in the patient’s medical records for future
reference.
9.
DUTIES/RESPONSIBILITES AND ACCOUNTABILITY
9.1.
All healthcare practitioners need to use their judgement to ensure that any care
provided is in the best interest of the patient.
9.2.
All prescribers are accountable for ensuring all relevant information has been
included on the remote prescription.
10.
ROLES AND RESPONSIBILITIES OF THE SENIOR MANAGEMENT
10.1.
The Head of Medicines Management is responsible for ensuring that there are
robust policies related to medicines safety for contractors to the CCG to access and
adopt.
11.
COMMITTEE WITH OVERARCHING RESPONSIBILITY FOR SUBJECT
11.1.
Medicines Group(s), with reports to the Clinical Governance Groups as assurance.
12.
INTERNAL COMMUNICATION
12.1.
The Head of Medicines management will communicate with the Risk manager and
any relevant health professional group to ensure appropriate CCG actions for risks
and medicines safety issues.
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NHS Dorset Clinical Commissioning Group
13.
TRAINING AND CONTINUING PROFESSIONAL DEVELOPMENT
13.1.
All Health Professionals contracted to provide services to the CCG are responsible
for maintaining their own CPD, and seeking updates when alerts arise. The CCG will
provide direction to suitable resources if appropriate.
14.
PROCESS FOR COMPLETING RISK ASSESSMENTS IF APPLICABLE
14.1.
If a contractor to the CCG identifies a specific risk highlighted by a medicines safety
alert or incident, then they should undertake risk assessments as appropriate for
their practice.
15.
MONITORING COMPLIANCE WITH THE PROCEDURAL DOCUMENT
15.1.
Audit against the standards in the policies provided should form part of contractors
routine clinical audit program.
16.
REFERENCES
Standards for Medicines Management (Nursing and Midwifery Council (NMC), 2010
Royal Pharmaceutical Society of Great Britain: Medicines Ethics and Practice: A Guide for
Pharmacists. July 2010 (subscription only)
Prescribing guidance: Remote prescribing via telephone, video-link or online
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NHS Dorset Clinical Commissioning Group
APPENDIX 1 FAXED / EMAILED REMOTE PRESCRIPTION FORM
Type of remote prescription
Verbal message
Fax
For verbal messages: Registered Nurse taking the message
Name
Date & time of message
Patient details
Patient name
Identifying number on system for patient:
NHS No. (if known)
Hospital No. (if known)
Date of Birth
Known allergies
Previous adverse reactions to medication
Drug name
Route of
administration
Drug strength
Frequency
Reason for remote prescription (also complete significant event form if appropriate)
Prescriber details
Prescriber name
Prescribing identification number (PIN)
Contact telephone number
Date
Follow up
Prescription provided?
Yes
No
If yes, enter date prescription was provided
If no, enter reason why prescription was not
provided
Signed
A copy of this form should be kept in the patient’s medical records
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Checklist for the Review and Approval of Procedural Documents
Yes/No/
Unsure
Title of document being reviewed:
1.
2.
3.
4.
5.
6.
Medicines Code Chapter 3: Policy for
Remote Prescribing
Is the title clear and unambiguous?
Is it clear whether the document is a
guideline, policy, protocol or standard?
Rationale
Comments
Yes
Yes
Are reasons for development of the
document stated?
Yes
Are individuals involved in the
development identified?
Is there evidence of consultation with
stakeholders and users?
Evidence Base
Is the type of evidence to support the
document identified explicitly?
Are key references cited?
Are local/organisational supporting
documents referenced?
Approval
Does the document identify which
committee/group will approve it?
Process for Monitoring Compliance
Are there measurable standards or KPIs to
support monitoring compliance of the
document?
Is there a plan to review or audit
compliance with the document?
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
January
2017
Review Date
Committee Approval
If the committee is happy to approve this document, please sign and date it and forward
copies to the person with responsibility for disseminating and implementing the document
and the person who is responsible for maintaining the organisation’s database of approved
documents.
Name
Date
Katherine Gough
Signature
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March 2015
NHS Dorset Clinical Commissioning Group
Equality Impact Assessment Form
Title of Document: Medicines Code Chapter 3 – Policy for Remote Prescribing
What are the intended outcomes of this work? Include outline of objectives and function aims
The document sets out the policy for provision of a remote prescriptions in Dorset CCG.
Who will be affected? e.g. staff, patients, service users etc
All staff in Dorset CCG.
Evidence
What evidence have you considered?
Disability Consider and detail (including the source of any evidence) on attitudinal, physical and
social barriers.
Not relevant.
Sex Consider and detail (including the source of any evidence) on men and women (potential to link
to carers below).
Not relevant.
Race Consider and detail (including the source of any evidence) on difference ethnic groups,
nationalities, Roma gypsies, Irish travellers, language barriers.
Not relevant.
Age Consider and detail (including the source of any evidence) across age ranges on old and younger
people. This can include safeguarding, consent and child welfare.
Not relevant.
Gender reassignment (including transgender) Consider and detail (including the source of any
evidence) on transgender and transsexual people. This can include issues such as privacy of data and
harassment.
Not relevant.
Sexual orientation Consider and detail (including the source of any evidence) on heterosexual people
as well as lesbian, gay and bi-sexual people.
Not relevant.
Religion or belief Consider and detail (including the source of any evidence) on people with different
religions, beliefs or no belief.
Not relevant.
Pregnancy and maternity Consider and detail (including the source of any evidence) on working
arrangements, part-time working, infant caring responsibilities.
Not relevant.
Carers Consider and detail (including the source of any evidence) on part-time working, shift12
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patterns, general caring responsibilities.
Not relevant.
Other identified groups Consider and detail and include the source of any evidence on different
socio-economic groups, area inequality, income, resident status (migrants) and other groups
experiencing disadvantage and barriers to access.
Not applicable
What is the overall impact? Consider whether there are different levels of access
experienced, needs or experiences, whether there are barriers to engagement, are there regional
variations and what is the combined impact
No impact
Addressing the impact on equalities Please give an outline of what broad action you or
any other bodies are taking to address any inequalities identified through the evidence.
Name of person who carried out this assessment:
Katherine Gough
Date assessment completed:
February 2015
Name of responsible Director:
Sally Shead
Date assessment was signed:
March 2015
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