Medicines Code Chapter 3: Policy for Remote
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. 1 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 2 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 3 NHS Dorset Clinical Commissioning Group 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; 4 NHS Dorset Clinical Commissioning Group 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. 5 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.” 6 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 7 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. 8 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 9 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 10 NHS Dorset Clinical Commissioning Group 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 11 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 NHS Dorset Clinical Commissioning Group 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 13
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