The PDA feel that this guidance document needs a substantial review as it is, overall, vague and ambiguous. We recommended that the GPhC should not publish a document based on this consultation but consult again in the future on a revised document.
Other key recommendations included:
- The guidance document for pharmacist prescribers should address the nuances of prescribing in different settings, and the specific activities to which pharmacists’ roles are suited, providing specific tailored guidance relevant to each. This may include, for example, guidance around repeat prescribing, working alongside GP colleagues to discuss cases and jointly agree individual patient plans, and dealing with secondary care letters and discharge recommendations.
- Under “Keeping up to date and prescribing within your level of competence”, the sentence “Pharmacist prescribers must regularly check that they are covered by their professional indemnity insurer for any additional or different prescribing roles they undertake, and review their cover as appropriate” should be changed to “Pharmacist prescribers must, having first ensured that they are competent to undertake a particular activity before doing so, check that they are covered by their professional indemnity insurer for the activities they undertake, and review their cover as appropriate. This includes in respect of any additional or different prescribing roles they undertake.”
- The GPhC should produce a ‘standard template scope of competence’ document with guidance around how to demonstrate competence in prescribing. This would assist pharmacist prescribers to ensure that they only practice within their competence and provide a tool to review and develop competence over time.
- Under “Prescribing in certain circumstances”, the GPhC should include a robust repeat prescribing protocol.
- Under “Prescribing non-surgical cosmetic medicinal products”, the GPhC should set an explicit requirement that pharmacist prescribers have appropriate training to identify patients with mental health conditions such as body dysmorphia, low self-esteem and other vulnerabilities. This should help ensure prescribing of cosmetic products is appropriate. Pharmacist prescribers should identify other treatment options for those patients, where necessary.
- The section “Information for pharmacy owners and employers of pharmacist prescribers” appears to specifically relate to pharmacy owners, yet most pharmacist prescribers will not currently be working solely in a registered pharmacy.
- A further section should be added to the guidance which sets out the responsibilities of GP practices, care home owners and hospital trusts, for example, in relation to pharmacist prescribers. The GPhC must set out how it works with the CQC and other regulators to ensure the regulation of such premises and relevant healthcare professionals takes the activities of pharmacist prescribers into consideration.
DOWNLOAD THE PDA’S FULL RESPONSE HERE
DOWNLOAD THE GPHC CONSULTATION DOCUMENT HERE
