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Q & A - Prescribing  

Index
PE503 - Sale of alternative medicines  
PE502 - MMR and PGDs  
PE501 - Prescriptions for care home  
 

Q PE503 - Sale of alternative medicines - Our practice would like to sell alternative medicine, such as glucosamine, at the surgery. Is this permitted?                                                                     New  07/07    

Answer – Since you are permitted to prescribe Glucosamine tablets on the NHS it would be considered part of normal GMS care. On this basis you are not permitted to charge for providing these medications.   

The concern with providing other non prescription alternative medicines for sale is that this would tend to imply that the doctor was recommending them. This may carry a risk to the professional reputation of the doctor in the absence of adequate evidence of safety and effectiveness and could lead to complaints and/or litigation in the event of an adverse reaction. Wessex LMCS would not recommend selling these medications but if you choose to proceed you should first seek the advice of your medical defence organisation.  

CED   

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Q PE502 - MMR and PGDs - Does our PGD cover the use of the American and German vaccines that have been brought in to make up for the shortfall in the supply of licensed MMR vaccines?    
                                                                                    
New  06/06   

Answer – Our local Communicable Disease centre has recently drawn our attention to this potential problem. These imported vaccines are not licensed in this country and therefore it is very unlikely that your nurses would be covered for administering them under your existing PGD. They should only be administering them under prescription. We have been assured that the vaccines are entirely safe and that it is perfectly permissible for the GP to prescribe immunisation for a number of named patients and to delegate the administration to the practice nurse.  You should therefore draw up a list of the patients due to receive the vaccine and the doctor should sign on the day of the clinic to authorise the administration. The list must include adequate patient identifiers such as name, date of birth, name of the product and dose.  

As a safeguard the nurse should explain to each patient before administration of the immunisation that there is currently a shortage of MMR vaccine in the country and that the product imported to make up the shortfall is currently unlicensed in the UK, but is considered to be safe to use. If the patient,or the responsible parent in the case of a child, agrees to vaccination this may then be taken as explicit consent and should be recorded in the medical record.

Footnote: 
One of our GPs checked with her medical defence organisation and was told that information provided by the DOH, and the fact that a substantial number of doctors were giving the vaccines believing then to be safe, would be useful backup in the event of a challenge. They stressed that it was essential to inform patients that the vaccine is unlicensed and to obtain explicit consent before giving the vaccine. 

The GPC has asked the DOH to indemnify GPs against the potential risk of using these unlicensed vaccines, but so far the DOH has failed to do so.  If you are concerned about the medico legal risk it would be sensible to seek and follow the specific advice of your medical defence organisation.

Further Information:  
Further Information on Supplies and Administration of MMR Vaccine

CED   

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Q PE501 - Prescriptions for care home – A local residential unit for young people is insisting that we fill out and sign the unit’s own prescription forms to allow them to administer the medication to patients aged 10 -15yrs.  Our practice has provided FP10s.  Do we have to fill out and sign these forms?                             New  17/05    

Answer - There is no GMS obligation to fill in the unit's individual prescription sheets.  If you are retained by the unit to provide a private service then they may of course insist that you do so if this is explicit or implicit in your contract.  

The problem is that the The Care Homes Regulations 2001 specify that residential homes must have a written service user's plan and strict written protocols on the use of medications.   In addition the UKCC insists that nurses must have clear written instructions if they are to administer a patient's medication. This puts the unit into something of a cleft stick.  

It is probably in the patient's best interests to have a clear written instruction on the unit's standard care or prescribing sheets to ensure full compliance with your prescribing instructions, but this is a personal professional decision.    

Perhaps a compromise could be agreed whereby the home would complete the prescribing sheet in compliance with your FP10 prescriptions and could bring the sheet to your surgery for you to countersign this as accurate?   

CED               

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