Medicines

Patient Specific Direction (PSD)

A PSD is the traditional written instruction from a prescriber for medicines to be supplied or administered to a specific patient/service user. The preferred option is for medicines to be supplied or administered by way of individual prescriptions or a patient specific direction, for example, written in a service user’s care record. This mechanism allows any suitably trained member of staff in health or social care to administer medicines that have been prescribed by an authorised prescriber for a specific individual. The medicines can then only be given to that named person.

Patient Group Direction (PGD)

A Patient Group Direction (PGD) is a signed, written document supported by a legal framework that allows named, authorised and registered health professionals (including occupational therapists) to supply and/or administer specified medicine(s).  The specified medicines are supplied/administered to a pre-defined group of patients with conditions described and detailed within the PGD.  An authorised PGD within a service enables the named, authorised health professionals to supply and/or administer medicines without the requirement to consult a doctor or dentist.  For more details on PGDs please refer to the information found at this link.

Supplementary Prescribing

Since 2005 Supplementary Prescribing has been open to physiotherapists, radiographers, podiatrists, chiropodist and optometrists but not to occupational therapists. It is a voluntary prescribing partnership between the patient, an Independent Prescriber and a Supplementary Prescriber to implement an agreed patient specific clinical management plan. The Supplementary Prescriber can then prescribe any medicine that is referred to in the plan until the next review by the Independent Prescriber. It is particularly useful for specific long-term conditions and in mental health.

Independent Prescribing

Independent Prescribing allows certain healthcare professionals (doctors, nurses, dentists, optometrists, pharmacists, physiotherapists and podiatrists (the latter two since 2013) to take responsibility for the assessment of patients with undiagnosed and diagnosed conditions and for decisions about clinical management required including prescribing. It is not currently open to occupational therapists. The scope of prescribing is slightly different between these different professions. Higher Education Institutes offer a specific programme of preparation and training for Non-Medical Independent Prescribing. These courses are approved by the professions regulatory bodies and individuals must register their prescribing qualification with their regulatory body before they can start prescribing.  Further information can be found at this link.

Medicines Act Exemptions

A number of health professionals have specific exemptions in medicines legislation which allow them to supply or administer medicines for example, podiatrists, midwives and paramedics. Some exemptions require an additional professional qualification. Exemptions enable the professional concerned to provide medicines which are basic to their professional practice without the need to refer to a prescriber, e.g. paramedic administration of pain relief after a road accident. Article 7 of the Prescription Only Medicines (Human Use) Order 1997 allows any person to administer certain medicines if it is for the purpose of saving a life in an emergency e.g. Adrenaline/Epinephrine. Practitioners should check their local policies in relation to this.

To confirm Supplementary Prescribing and Independent Prescribing are not currently available to occupational therapists in any of the four UK nations. To support those allied health professions that do have prescribing responsibilities the Health and Care Professions Council (HCPC) have published a set of standards for prescribing available here.

Patient Specific Direction (PSD)

The following example demonstrates the use of PSDs on a mental health rehabilitation ward:

PSDs are used by an occupational therapist on a mental health rehabilitation ward in a hospital in Devon, preparing patients for discharge to the community.  The PSDs are written up by a prescriber, and the occupational therapist observes patients self-medication.  The occupational therapist is assessing the impact of medicines on functional ability and readiness to move onto the next stage prior to discharge – with the patient independently managing medication.  It is anticipated at this stage that regular medication is maintained to give them consistency, with the support of staff.  Both physical and mental health needs are considered to contribute to multidisciplinary (MDT) discussion regarding any changes to medication prior to discharge.  Due to the amount of time spent in a hospital setting, some people find everyday structure and basic life choices a challenge.  This approach aims to allow patients to take responsibility for everyday tasks, including taking medication. 

Patient Group Direction (PGD)

Examples of PGDs used by occupational therapists include:

My manager (who is not an occupational therapist) has told me that I should discuss medication side effects with the people on my caseload.  Should I be doing this as an occupational therapist?

Regarding medication, occupational therapists frequently work with individuals whose needs or diagnoses cause them to be reliant upon one or more medicines for treatment, maintenance or emergency purposes. It is therefore important that all practitioners have a working knowledge of the medicines relevant to those they work with. Occupational therapists should have an understanding of the types of medicines used in relevant acute and long-term conditions, how they are used and their possible side effects. Practitioners should be aware that medicines can have a significant effect upon occupational performance, occupational engagement and occupational therapy intervention and outcomes.

What is RCOT doing regarding campaigning for occupational therapists to prescribe medications?

RCOT is currently working on medicines mechanisms including feeding into any possible future change in legislation regarding supplementary and independent prescribing for occupational therapists, and the College will be publishing further resources concerning occupational therapists and prescribing responsibilities in the future.  RCOT welcomes examples of the potential for occupational therapists to use prescribing to improve patient care and service capacity.

Is medication management considered to be within the scope of practice of an occupational therapist?

Practitioners must consider whether their work can be considered as within the scope of occupational therapy practice. At the heart of occupational therapy is the belief that the ability to participate in meaningful occupation is fundamental to health and wellbeing, and that occupation in itself has therapeutic value. The profession’s core skills focus on the assessment of occupational needs and the facilitation of occupational performance/engagement. Any activity that an occupational therapist uses or does therapeutically, in order to enable or enhance occupational performance, may be considered within the professional scope of practice.  Practitioners must be able to demonstrate that their professional rationale for any activity or intervention is the enhancement of health and wellbeing through the promotion of occupational performance/engagement. The title of the practitioner’s job is not relevant to this decision.

The occupational therapist’s employer should have vicarious liability insurance for them. If they are a member of RCOT and they can demonstrate that their professional rationale for any activity or intervention is the enhancement of health and wellbeing through the promotion of occupational performance/engagement, the RCOT Malpractice and Professional Liability and Public and Products Liability Insurance will also provide cover. Either or both of these schemes will provide appropriate professional indemnity insurance for them.

I’m not very confident regarding discussing medication issues with the people on my caseload.  I’m worried that I may make mistakes.  What should I do?

The Code of Ethics and Professional Conduct (2015) states regarding professional competence: 
 

5.1: You must only provide services and use techniques for which you are qualified by education, training and/or experience.  These must be within your professional competence, appropriate to the needs of the service user and relate to your terms of employment.

5.1.1: You should achieve and continuously maintain high standards in your professional knowledge, skills and behaviour.

5.1.2: You should be aware of and abide by the current legislation, guidance and standards that are relevant to your practice, remaining up to date with relevant training where necessary.

5.1.3: You should understand the scope and benefits of emerging information and communication technologies to ensure that you make the best use of what is available in your own practice, or through referral to other agencies.

5.1.4: If you are asked to take on additional tasks, such duties should be only undertaken after discussion, considering additional planning, support, supervision and/or training.

5.1.5: Adequate training and support should be provided to enable you to be competent to carry out any additional tasks or responsibilities asked of you.

5.1.6: You should be given the opportunity to raise any concerns and be provided with the rationale behind the original request.  If you find that you cannot agree to such a request you should contact your local union representative for advice and support.

5.1.7: If you are seeking to work on areas with which you are unfamiliar or in which your experience has not been recent, or if you take on a more diverse role, you must ensure that you have adequate skills and knowledge for safe and competent practice and that you have access to appropriate support.

6.2.1 You only provide services and use techniques for which you are qualified by your professional education, ongoing learning and/or experience. These must be within your professional competence, appropriate to the needs of those who access the service, and relate to your terms of employment. 

6.2.2 You have sufficient knowledge, skills and experience to make reliable professional judgements, suitable to your level of responsibility and scope of practice.

6.2.4 You are attentive to and abide by the current legislation, guidance and standards that are relevant to your level and scope of practice and place of work.

6.3.10 You keep up to date with digital skills, understanding the scope, benefits and potential impact of emerging digital technologies to ensure that you can make best use of what is available.

6.4.1 If you seek or are asked to work in areas within which you have less experience, you ensure that you have adequate skills and knowledge for safe and effective practice and that you have access to appropriate supervision and support (see Section 6, point 6.2).

6.4.2 You assess any possible risks in taking on a different role or responsibilities, to ensure that you provide a safe service.

6.4.3 If you are asked to act up or cover for an absent colleague, or if you are asked to take on additional tasks, such duties are only undertaken after discussion, considering additional planning, support, supervision, and/or learning and development requirements.*

6.4.4 You ensure that adequate support and learning opportunities are provided to enable you to carry out any additional tasks or responsibilities safely and effectively. 

6.4.5 You formally raise any concerns you may have about your capability to carry out any additional tasks or responsibilities.

Patient Group Directions (PGDs) and Occupational therapists

RCOT Informed View: Medicines Mechanisms

HCPC – Standards for prescribing

Royal Pharmaceutical Society Medicines Optimisation

Potential future use of medicines mechanisms by occupational therapists:

Increased responsibility for occupational therapists in the use of medicines mechanisms could support new roles and new ways of working to increase the capacity, capability and flexibility of the workforce.

Occupational therapists’ ability to supply and administer under PSDs and PGDs, although useful in certain settings, has its limitations, and with greater responsibility there is potential to think more creatively about service delivery.

Much of the work of occupational therapists is now within community settings, and this will continue to increase e.g. in people’s homes, care homes, schools, primary care and community centres.As such, for occupational therapists to carry and use current medicines mechanisms in these settings, consideration would need to be given to secure storage, supply and administration mechanisms.

With changes to medicines mechanisms legislation and the repurposing of the current workforce, so that it has the skills required to deliver new models of care, occupational therapists could extend their role and improve service delivery.

What is RCOT doing regarding campaigning for occupational therapists to prescribe medications?

The current proposed Medicines and Medical Devices Bill would give the government powers to more freely amend prescribing responsibilities. RCOT are regularly meeting with DHSC civil servants, NHS officials and Ministerial staff to make the case for our profession to be prioritised in the next round of prescribing responsibility expansion.  

To support this work, RCOT welcomes examples of the potential for occupational therapists to use prescribing to improve patient care and service capacity.

Examples should include information on the following:

• Medicine/group of medicines
• Medicine Mechanism(s) – may or may not be identified at this stage
• Patient group/specialty
• The difference it would make

The template below is available for members to use and distribute.