DDA response to the Consultation on proposals to introduce independent prescribing by pharmacists

On the 28th of February 2005 the government and the Medicines and Healthcare Products Regulatory Agency (MHRA) opened a Consultation on proposals to introduce independent prescribing by pharmacists. The DDA have responded on behalf of members. The proposals will affect all parts of the United Kingdom. Following the consultation implementation of any proposals will occur later in 2005 via a Statutory Instrument.

Our response was written by Dr David Baker , the DDA CEO.

31 May 2005

We feel there is a fundamental difference between a pharmacist working in secondary care as part of a multidisciplinary team and an independent community pharmacist working from premises in the High Street. It is essential that any change in the regulations takes account of their different working practices.

Whilst welcoming the involvement of pharmacists as an integral part of the primary health care team, and appreciating there is a desire by pharmacists to prescribe, we question the absolute "need" for pharmacists to prescribe.

Patient benefits will only accrue if pharmacists act as part of an integrated health care team with free interchange of, and access to information.

We are concerned that the whole tenor of the consultation document shows a preference for the introduction of some form of independent prescribing by pharmacists. All the benefits are mentioned, but little is said of the problems that could accompany the proposed changes. We have major concerns in the following areas:

Diagnosis

Doctors are fully trained in diagnosis - the same is not true of pharmacists. It is essential for patient safety that a working diagnosis should remain the cornerstone of treatment; the training, facilities and experience available to pharmacists working independently, do not at present meet this criterion.

Legal Liability

It is essential that all independent prescribers take full responsibility for their actions and that the possession of comprehensive indemnity insurance must be a condition of any extension of prescribing rights.

With a number of people prescribing for a patient, who takes responsibility when things go wrong? In our view there has to be a clearly defined chain of responsibility. We believe most patients would prefer such responsibility to remain, as at present, with their doctor.

Patient Record

Without a common patient record accessible by all users, independent prescribing by pharmacists or any other group has potentially dangerous consequences for patients. The technical difficulties surrounding the creation of an Electronic Patient Record coupled with confidentiality and privacy issues mean that it will be some time before free and full interchange of data between all those treating a patient becomes possible. We acknowledge that in a hospital or in other health care team situations such access to records is already possible.

Until these issues are resolved, we feel there should be no extension of independent prescribing.

Dispensing by Doctors

For many years, when dealing with dispensing doctor issues, governments of every hue have repeated the mantra that, "doctors prescribe and pharmacists dispense." If the outcome of this consultation is an extension of pharmacist prescribing then the mantra must be ditched. It would be entirely logical for doctors dispensing to be extended and patients to be given the same access to over the counter and other non-prescription medicines directly from their doctor.

 Dr Richard West (right), DDA Board member said, "Prescribing for one condition may well affect other conditions that the patient has, it is important that the prescriber is fully aware of the possible adverse outcomes of their prescribing particularly now that many patients have multiple pathologies. It comes back to the mantra first do no harm. If other professional are going to prescribe they need an extensive training programme."

Dr Malcolm Ward felt that limited pharmacist prescribing for minor illnesses would be acceptable.

To find the consultation document go to http://www.dh.gov.uk and then click on consultations, followed by closed consultations.