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Vol 274 No 7331 p8-9
1/8 January 2005

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News feature

Independent prescribing draws closer

A Government consultation on independent prescribing by pharmacists is about to be published. Clare Bellingham (on the staff of The Journal) talked to some pharmacy opinion leaders about the issues that the consultation will address and how independent prescribing might develop

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Department of Health: Prescriptions and prescribing (more)


New prescribing rights to come in 2005

New prescribing rights to come in 2005

Independent prescribing is undoubtedly going to be one of the hot topics for the profession in 2005. Less than a year after the first pharmacist wrote a prescription as a supplementary prescriber (PJ, 27 March 2004, p369), a consultation on independent prescribing by pharmacists is about to be published.

Providing there are no unforeseen hurdles, independent prescribing will be introduced later this year. According to a Department of Health spokesman: “Subject to ministerial agreement and Parliamentary approval, we expect the necessary statutory and regulatory changes to be completed in 2005.”

But before then, a number of issues need to be considered. The first step has already taken place: a scoping exercise in which the Government privately consulted with key members of the profession. Next is the public consultation. The DoH could not give a publication date, but it is thought it might be as early as next week.

It is hard to predict what issues the consultation will consider. However, by talking to people who participated in the scoping exercise, as well as some opinion leaders in the profession, a clear picture emerges of how independent prescribing might develop.

Two central themes have come up time and time again: the need for a clear definition of “independent prescribing” and whether or not pharmacists should be restricted to
prescribing within a formulary.

The benefits of extending independent prescribing to pharmacists are far-reaching.

“Independent prescribing will allow pharmacists to achieve what many have said is their true role — being the experts in medicine — and have this role recognised by the health care service and public alike,” says Nigel Simmons, non-medical prescribing lead, Cambridgeshire. He says it is up to individual pharmacists to seize the opportunity. “All pharmacists should review their work practices and consider where they will be able to develop prescribing roles. The days of pick and stick must become a thing of the past if pharmacists are to show themselves as more than technicians or dispensing assistants,” he comments.

David Pruce, director of practice and quality improvement at the Royal Pharmaceutical Society, explains that independent prescribing is a tool to enhance the services that pharmacists already provide. “For example, pharmacists are already involved in admission clinics but need a doctor to co-sign what they decide [to prescribe]. Similarly in chronic disease areas, it would be a better use of pharmacists’ skills if they could prescribe as well as advise. The result for patients would be a smoother service with fewer delays and the most appropriate professional making decisions.”

David Webb, director of clinical pharmacy, London, Eastern and South East specialist pharmacy services, says: “The topline benefit is improving the care given to patients. Independent prescribing by pharmacists will lead to better access to medicines and a potential improvement in safety of prescribing.” More controversially, he points out that it will lead to the legalisation of current practices that are outwith the Medicines Act.

The introduction of independent prescribing by pharmacists will undoubtedly increase patient choice, something that is high on the political agenda. “Patients choose to access services in different ways and pharmacist prescribing will add another alternative,” explains Ash Soni, National Pharmaceutical Association chairman. “So patients can choose who is best-placed to treat them at a particular time. Sometimes it will be a pharmacist, sometimes a nurse, sometimes a GP and sometimes another health professional like a dentist.” A document published by the NPA last month (PJ, 11 December 2004, p840) describes many of the benefits that independent prescribing by pharmacists could bring. Alongside increased patient choice, it highlights faster access to medicines, equity of access, reduced pressure on GPs, an ability to supply P and GSL medicines more widely (ie, according to their POM licence), and increased job satisfaction for pharmacists.

Independent prescribing model

What seems to be needed is a clear definition of “independent prescribing”. Alison Strath, principal pharmaceutical officer at the Scottish Executive, suggests that pharmacy needs a hybrid model of independent and supplementary prescribing. “One of the questions pharmacists will face in discussions over independent prescribing is ‘are you a diagnostician?’,” she says. “And while pharmacists can diagnose minor conditions, this is not necessarily the case in more complex areas of disease. So although independent prescribing for minor conditions could include diagnosis, I think that for complex conditions a diagnosis should be obtained from a medical practitioner first. The pharmacist would then be free to pick the most appropriate treatment.”

In other words, it comes down to maximising the skills of each profession. Ms Strath points out: “Medics’ skills are in diagnosis. Pharmacists should come in after diagnosis and use their skills to fit the treatment to the individual patient.”

Mr Webb agrees: “What would really help is a less tightly controlled form of supplementary prescribing. So pharmacists work with medical colleagues who make the diagnosis but they have more freedom because a clinical management plan is not required.”

This view is echoed by Mr Pruce. He suggests that a different term to “independent prescribing” is needed. “The classical definition of independent prescribing includes making a diagnosis but the diagnosis may already have been made before the pharmacist independently prescribes.”

Formulary or not?

Pharmacy practice differs between sectors so it is likely that independent prescribing will develop in a number of ways.

“What suits one practice setting may not meet the needs of another,” Mr Webb explains. “For example, whereas a formulary approach might be useful in community pharmacy because of the parallels with nurse prescribing, this would not necessarily translate well into an acute care setting or for pharmacists working with GPs.”

Others disagree. “All pharmacists need to have access to the whole BNF and then they should work within their competencies,” Ms Strath says. “Restrictions would reduce the impact pharmacists could have on improving care.” Mr Simmons agrees that a fixed formulary would be too restrictive. “Once a formulary is established, it is a lengthy process to make changes. The best option is for an almost unlimited formulary, but with a requirement that prescribing only occurs within a framework of expertise and experience,” he says.

Perhaps lessons should be learnt from nurses who already have independent prescribing rights but who can only prescribe from a formulary. “Nurses are seeking to achieve prescribing powers for the full BNF,” says Mr Simmons. “If pharmacists accept a limited formulary, they will continue to be the ‘poor relation’ and only partial members of the patient care team.”

Mr Pruce suggests a balance. “We need to tailor what a pharmacist can prescribe to the service. So for areas such as discharge clinics or medication reviews, it would be difficult to see how the pharmacist could function properly with a restricted formulary. But in others, such as a minor ailments service, then a restricted formulary would work well.”

However, Mr Soni says: “The prescribing role should depend on the competency of the individual pharmacist and nothing else. We must be careful not to have separate formularies for community pharmacy, hospital pharmacy and primary care pharmacy because pharmacists move between sectors.” He adds that separate formularies could create problems for cross-sector working, something that is becoming increasingly common.

Using independent prescribing

How might independent prescribing be used? In hospitals, Mr Simmons suggests that pharmacists could become responsible for discharge and admission prescribing. Mr Webb suggests additional roles in prescribing drugs with narrow therapeutic indices and therapeutic substitution. He highlights subtractive prescribing (ie, crossing off items that are not appropriate or no longer needed) as an example of something that some pharmacists already do but, it could be argued, that by altering therapy in this way the pharmacist is acting as a prescriber. Independent prescribing rights would solve this problem.

In the community, independent prescribing would allow the pharmacist to become the first port of call for patients with acute illness, says Mr Simmons. “Prescribing would build on the existing advisory role for over-the-counter medicines but provide a much greater and more effective range of choices.”

Turning to the new pharmacy contract, Mr Pruce suggests that independent prescribing will be used within enhanced services. “One of the biggest barriers to implementing the outcomes of full medication reviews carried out by pharmacists is getting changes made on the GP computer systems. So we might see pharmacists doing reviews and then making changes to patients’ prescriptions.”

Other areas in which independent prescribing could be used are out-of-hours services and residential and nursing homes.

One issue that is certain to come up during the consultation is whether or not dispensing and prescribing need to be separated. And someone is likely to point out that dispensing doctors are responsible for both prescribing and dispensing so why place additional restrictions on pharmacists? However, few could disagree that, regardless of anything else, separating the functions is of clinical value.

Mr Simmons highlights skill mix as a solution. “With the moves towards registered technicians and the review of working practice from the skill mix consultation, it should be possible to create a safe working environment where prescribing and dispensing can take place in the same premises with a clear division of responsibilities as a governance and safety check,” he says.

Mr Soni comments that when a community pharmacist is prescribing in a consultation, it is most likely that a second pharmacist will be working in the dispensary. Therefore, it is unlikely that a pharmacist would prescribe and dispense.

In terms of financial incentives, Mr Soni suggests: “The solution is to give the patient a prescription and tell them they can take it to any pharmacy they choose.”

In Scotland, such incentives may be removed through the proposed new pharmacy contract. The contract (which is still subject to contractors’ approval) looks set to move away from payment by prescription volume to capitation fees for two of the four core services.“Pharmacist prescribing, both supplementary and independent, will, in future, provide significant support for the new chronic medication service (CMS) which is due to be funded through capitation,” explains Frank Owens, Scottish Pharmaceutical General Council chairman. “If contractors are to be given prescribing rights, and if we are to maximise the opportunities presented by these new rights, then we need to remove any perverse incentives to prescribe. Moving away from volume-based payments means that remuneration will not depend on the number of prescriptions a pharmacist writes. Instead, CMS fees will be based on the size of the patient population that pharmacy serves.”

Will new rights be the end of supplementary prescribing?

Few would disagree that supplementary prescribing has been essential in the road to introducing independent prescribing. Pharmacists had to demonstrate the contribution they could make by becoming prescribers. But the introduction of independent prescribing is certainly not the death knell for supplementary prescribing. Without doubt, supplementary prescribing has and is delivering improved patient care.

Supplementary prescribing enables pharmacists to manage long-term conditions within a clinical management plan. While some would say that the management plan is constraining, others argue that this is exactly what is needed to allow pharmacists to extend their practice in a way that they feel comfortable, and in a way in which doctors are confident.

David Webb, director of clinical pharmacy, London, Eastern and South East specialist pharmacy services, suggests that there is a role for both in the future. “Independent prescribing could be used for complete episodes of acute care but supplementary prescribing, used within a clinical management plan, is an important tool for longer-term care. It has an obvious place in the management of chronic conditions,” he explains. But he adds that the ongoing clinical management plan does not fit well with things like discharge prescribing and this is why there is a need for independent prescribing, too.

For the time being, pharmacists should continue to develop supplementary prescribing roles. At the same time, they can look forward to the end of 2005 when independent prescribing may become a reality.

Plenty of other issues exist. One is whether or not pharmacists should be able to prescribe antibiotics. Ms Strath believes that they should: “Pharmacists are thoughtful around antibiotic use, and are often at the fore of taking forward antibiotic prescribing policies,” she says. Citing the example of a patient with an infected bite from a pet seeking a pharmacist’s advice on a Saturday afternoon, she comments that preventing pharmacists from prescribing antibiotics in these situations and, instead, having to refer patients to accident and emergency does not make sense.

For prescribing in chronic disease to be successful, pharmacists need to have good, long-term relationships with patients. They need to see patients on a regular basis, giving them the opportunity to monitor and adjust medicines as appropriate. Many patients return to the same pharmacy time and time again, so perhaps now the time has come to consider introducing compulsory patient registration at community pharmacies. Mr Pruce says that the need for registration will depend on the specific service offered.

Then there is implementation. Beth Taylor, specialist principal pharmacist, London and South East regions, believes that implementation will be the biggest issue for community pharmacist prescribers. She points out that there is so much happening in primary care at the moment that primary care trusts are overloaded. In addition, she says: “There is an expectation that PCTs will fund chronic disease management services offered by pharmacists. But because chronic disease management is part of the essential service in the new GP contract, any activity that pharmacy can provide to support it could be funded through practice monies.”

Funding of independent prescribing services will certainly be an issue. Not only funding of the pharmacist’s role, but also the costs of prescribed drugs. There is also the possibility of private practice: preventing pharmacists from prescribing privately might hinder travel health services since most antimalarials are privately rather than NHS-prescribed.

And then there are workforce and training issues. Not all pharmacists will want to train as prescribers. This means that although one pharmacy might offer prescribing services, another down the road might not. This could confuse patients. Furthermore, if a prescribing pharmacist is on holiday, what happens to the service if the locum cannot prescribe?

There are many issues to consider. The consultation document and the debate that will follow should open a new chapter in pharmacist prescribing.

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