Controlled drugs and other medicines where additional safeguards are needed
Some categories of medicine may pose particular risks of serious harm or may be associated with overuse, misuse or addiction. When prescribing, you should follow relevant clinical guidance, such as drug safety updates on the risk of dependence and addiction associated with opioids.17
See MHRA safety drug update on opioids and risk of dependence and addiction.
If you don’t have access to relevant information from the patient’s medical records you must not prescribe controlled drugs or medicines that are liable to abuse, overuse or misuse or when there is a risk of addiction and monitoring is important.18 Exceptions to this are when no other person with access to that information is available to prescribe without unsafe delay and it is necessary to:
- avoid serious deterioration in health or avoid serious harm
- ensure continuity of treatment where a patient is unexpectedly without access to medication for a limited period.
General Pharmaceutical Council (GPhC) guidance on providing pharmacy services at a distance, including on the internet (April 2019) provides examples of relevant medicines. These include: opiates, sedatives, laxatives, pregabalin, gabapentin.
In these circumstances, you should provide a limited quantity and dose – one that is sufficient to make sure the patient receives suitable care until a) they are able to see an appropriate health professional who has access to the relevant information from their medical records or b) you are able to verify that information yourself. In making this decision you should consider the possibility that the patient may be obtaining medicines from other sources. You should also follow the guidance at paragraphs 56-58.
If you are prescribing remotely, you must also be satisfied that appropriate safeguards are in place to support safe prescribing. Relevant safeguards include:
- robust identity checks to make sure medicines are prescribed to the right person
- if you are not the regular prescriber, check to make sure the patient has given consent for their regular prescriber to be contacted about their prescription (see paragraph 27)
- making sure all relevant information about the prescription is shared with the patient’s GP or added to the primary care record (see paragraphs 56 to 57).
You should give the patient the names, roles and contact details of key people who will be involved in their care, as well as advice about who they can contact if they have any questions or concerns. This is particularly important if you are prescribing remotely.
You must not prescribe controlled drugs to yourself or someone close to you, except in the circumstances described in paragraph 69.
You must not prescribe medicines for your own convenience or the convenience of other health or social care professionals (for example, prescribing sedatives for the convenience of those caring for patients with dementia in care homes where there is no clinical justification.19
See ‘The use of antipsychotic medication for people with dementia: Time for action’ (Department of Health, 2009) and NICE’s guideline on dementia. The NICE website, the joint NHS Institute contains guides, case studies and other materials to support good prescribing practice and alternative care strategies for patients with dementia.
Pharmacies may not dispense some categories of medicine if they are prescribed remotely, unless certain safeguards are met.20
For further information see GPhC guidance on providing pharmacy services at a distance, including on the internet (April 2019). The Pharmaceutical Society of Northern Ireland (PSNI) provides guidance for pharmacies based in Northern Ireland.
Prescribing for yourself or those close to you
Wherever possible, you must avoid prescribing for yourself or anyone you have a close personal relationship with.
If you prescribe any medicine for yourself or someone close to you, you must:
- make a clear record at the same time or as soon as possible afterwards; the record should include your relationship to the patient, where relevant, and the reason it was necessary for you to prescribe
- follow the advice on information sharing and safe prescribing in paragraphs 27 to 33 and 53 to 58.
You must not prescribe controlled drugs for yourself or someone close to you unless:
- no other person with the legal right to prescribe is available to assess and prescribe without a delay
- emergency treatment is immediately necessary to avoid serious deterioration in health or serious harm.
Prescribing remotely for patients in a care or nursing home or hospice
If you are prescribing remotely for a patient in a care or nursing home or hospice, you should communicate with the patient, or if that’s not practicable, the person caring for them, to make your assessment and to provide the necessary information and advice. You should make sure any instructions, such as how to administer the drug or monitor the patient’s condition, are understood. And you should send written confirmation to them as soon as possible.
Prescribing remotely for patients based overseas
In addition to the above guidance, before prescribing remotely to patients who are overseas, you should also consider:
- how you or local healthcare professionals will monitor their condition
- differences in a product’s licensed name, indications and recommended dosage
- whether you have adequate insurance or indemnity arrangements in place to cover your practice in all relevant countries
- whether you need to be registered with multiple regulatory bodies, including in the country you are based, in the country the patient is based, and in the country where the prescribed medicines are to be dispensed.
You should also follow UK and overseas legal requirements as well as relevant guidance on import and export for safe delivery, including from the MHRA.
If you are considering working for service providers based outside the UK, it’s important to be aware that there may not be established local mechanisms to provide effective systems of regulation and this may have an impact on patient safety.
