Theoretically, the Human Medicines Regulations will allow registered pharmacy technicians to lawfully supply and administer medicines under a PGD in the course of their practice. In Northern Ireland, pharmacy technicians are not regulated and therefore fall outside of the scope of this advice.
In a practical sense, it is crucial to understand the additional steps that need to be put in place before there is a change to day-to-day community pharmacy practice.
Current service directions and specifications for community pharmacy NHS commissioned services will likely not permit PTs to work under them. These issues will need to be addressed during negotiations, and if agreed upon, will be amended accordingly. Information can be expected in due course from the respective country pharmacy negotiating bodies.
Advice to PDA members
The current community pharmacy NHS commissioned services that utilises a PGD as part of it does not allow PTs to deliver it and stipulates that a pharmacist must deliver these. Consequently, it will be premature to offer specific operational advice to pharmacists involved in the delivery of current community pharmacy NHS commissioned services, involving PGDs. However, at this point, it is worth reminding members of some important principles.
A PGD is, as far as the medicines legislation is concerned, a legal mechanism by which certain (generally POMs) medicines can be supplied without a prescription.
During the work undertaken by the sector group on supervision in community pharmacy and in the subsequent Department of Health and Social Care (DHSC) consultation, which will define how pharmacists are to supervise medicines supplies in community pharmacy in the future, two components of safe medicines supply were identified:
- The preparation, assembly, sale, and supply of medicines. This includes an accuracy check, activities that could be undertaken by registered pharmacy technicians.
- The undertaking of a clinical assessment. An activity that is reserved solely for pharmacists because of their more appropriate and comprehensive training and qualifications.
A study of the PGDs indicates that with few exceptions, the delivery of medicines via a PGD requires there to be a clinical assessment of the patient. This is to not only to establish a diagnosis and therefore to choose the right PGD, but there is also the need to ensure that there are no wider concerns such as an interaction with a potentially extensive and complex polypharmacy regime or associated co-morbidities.
Unlike a dispensing process, a PGD cannot be broken down and delivered in small distinct pieces. Under PGD regulations, they are designed to be delivered as one episode of care by one person. Consequently, when the patient safety consideration logic on medicines supply carries through to PGDs it dictates that only pharmacists should be delivering any PGD that involves an element of clinical assessment.
The PDA will provide an update once the NHS service specification is agreed and becomes available.
Learn more
- Government must listen to the pharmacists’ representatives who understand patient safety risks when looking at the pharmacy technician agenda
- PDA writes to Pharmacy Minister about the differences between pharmacists and pharmacy technicians
- PDA cannot support the Department of Health and Social Care proposal for the use of patient group directions by pharmacy technicians
- PDA release their Pharmacy Technicians Report in its entirety
- Pharmacy supervision
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