Green Elms Practice PCT Remedial Notice: RM/CM5 Repeat Prescribing Review 27 November 2009 Dr Mark Greenhalgh Medical Director, ChilversMcCrea Healthcare Background This brief report summarises a review of the repeat prescribing processes at Green Elms Health Centre carried out in response to NHS North East Essex Remedial Notice RM/CM5, dated 7th October 2009. As part of a wider review, Dr Greenhalgh visited the practice with Dr McCrea on 23rd November 2009. Interviews with staff and examination of the systems and processes were undertaken. Repeat prescribing was assessed against the existing ChilversMcCrea Healthcare Repeat Prescribing Policy, dated January 2009. Between April 2002 and December 2006, Dr Greenhalgh was Prescribing Lead at Epping Forest / West Essex PCT and is a Partner at Keyhealth Medical Centre. Repeat Prescribing The review and this report have been structured to reflect the framework of the CMH repeat prescribing policy, which sets out four stages for control and management: 1. Initiation / Request 2. Production / Authorisation 3. Clinical control / Review 4. Management Control 1. General CMH Standards: In general the policy emphasises that a GP should retain active involvement throughout the process and should not delegate any entire part of the processes to ancillary staff. In particular, the policy states that the following should be entirely the responsibility of the GP. • Initiation • Authorisation • Clinical control / review Compliance at Green Elms: The overall nature of repeat prescribing has not complied fully with the standard set out in the policy in the sense that it could be demonstrated that prescription requests would
be initiated and agreed / issued without full and active involvement of a GP. This has included the signing of prescriptions for newly requested medicine, prepared by ancillary staff, without recourse to the medical record or communication with the patient by the signing doctor. 2. Initiation / Request CMH Standards: The policy requires that the decision to put a drug on the repeat list for a patient must always be made by a doctor after appropriate review and that care should be taken to ensure accuracy, suitability and be part of the computerised record. The standard requires for patients to be provided with a printed repeat slip and to be actively involved and responsible in requesting their medication. The policy does not allow for telephone requests, except under exceptional circumstances and for housebound patients. The policy requires patients to be encouraged to advise if their medication is no longer needed. Compliance at Green Elms: Many new patients’ medication is entered by the GP at initial consultation and it is assumed for the purposes of this report that suitable checks and assessments have been performed by the GP at that time. Some new patients to the Practice are in possession of a Part B (printed repeat list) from their previous surgery, and in these cases it has been usual for the repeat medication to be entered into the clinical system by the prescription clerk. In these cases, it would not usually be the case that a doctor routinely or systematically checked the medicine before being issued. Where a doctor has decided that an acute prescription is suitable for transferring to being a repeat medicine, the usual review period defaults to six months, which is an appropriate default. This process was not directly assessed as part of the review, either by audit or interview, since most of the doctors at the practice have only recently come into post. Patients seem to be aware that their medication requests should be in writing and there was no impression gained that telephone requests were routine, which is as it should be. The processes for ensuring the secure handling of requests have recently been improved, significantly reducing the loss of request slips, improving the confidentiality of information and cutting down on time wasted by having to search for missing slips and handle queries. Green Elms has not fully complied with the standard set out in the policy, since while all repeat medication is handled via the computerised record system, with requests handled for the most part in writing, it could not be demonstrated that the suitability and accuracy of all repeat medication has been checked by a doctor after appropriate review for all patients. Patients do routinely receive a printed request slip and initiate their own requests. Recent improvements to handling requests have been made.
3. Production / Authorisation CMH Standards: The policy requires that requests be made using pre-‐printed forms rather than being handwritten to minimise errors, that compliance checking is undertaken in order to highlight under or over use and that the process is the responsibility of a prescriber. Attention is drawn to early requests as an indication to check over-‐use. While allowing the routine production of prescriptions by a receptionist for subsequent signing, the policy sets out situations where the record should always be consulted, including: review period expiry, request for medication not previously taken by the patient, requests for certain specified drugs, recent issue less than one month previously and all controlled drugs. The standard also sets out and reflects accepted good practice for handling of prescriptions. Compliance at Green Elms: The practice has generally complied with the standard by issuing Part B slips, and the prescription clerk is in the habit of flagging up over-‐use when requests are made early. However, no systematic attention is being given to identifying under-‐use. This can be done at a variety of points, including during medication review and chronic disease management checks, neither of which have been demonstrated to be reliably nor regularly carried out across all common chronic disease areas. (This is significant, for example, in asthma management or hypertension control). It is unclear whether the records have been reliably consulted in accordance with the policy standard under the situations required, although it is likely / possible that this has not always been done. It is the case though, that new drug requests have been made, and actioned through the prescribing system, without a corresponding clinical note being made by the doctor. Prescriptions have been prepared by the prescribing clerk for signature, typically accompanied by a sticky note stating the reason for the request. It was not demonstrated that these explanatory notes have made it into the clinical record, either directly or indirectly, or that the authorising prescriber has necessarily taken proper (full, active, informed) clinical responsibility for the issue of the drug. This is an important area where Green Elms appears not to have adhered to CMH policy standards. Other aspects of prescription handling have generally been good. Concerns were expressed, and audit has revealed, that whilst prescriptions have been generated and collected by local pharmacies, they have not always been accounted for afterwards. The practice has adopted an approach of ensuring that re-‐printed prescriptions are marked as duplicate and anecdotally this has reduced the problem. Uncollected repeat prescriptions are handled correctly and not stored past four weeks. 4. Clinical Control / Review CMH Standards: The policy emphasises that this is a clinical responsibility, to be exercised mainly by prescribers. The standard is for 28-‐day cycles and supply, with a small number of suitable exceptions. Supply is required to be synchronised where possible. The policy requires that all medication be reviewed when a patient is discharged from hospital and
makes the point that this is a vulnerable time for errors to be made, since safe practice relies upon good communication between hospital, GP and patient. The CMH standard is that a doctor amends the record personally, in order to ratify the decision and to re-‐ authorise. The same principles apply to clinic letters, which may specify a change in medication. The policy draws attention to various considerations to be borne in mind by the reviewer of repeat medication, including optimising control of the condition, avoiding unnecessary medication, compliance, monitoring requirements and cost factors. Compliance at Green Elms: It would appear that 28-‐day prescribing is the norm, however, this can easily be confirmed by assessment of ePACT prescribing data, which was not reviewed at this visit. There has been no system to review medication changes resulting from either hospital discharge or clinic attendance. Although incoming letters have been viewed and often initialled by a doctor, in most cases it seems to be the case that medication changes are not made at the time. A more usual scenario described is that the patient has subsequently advised that their dispensed medication does not match what they were told at discharge or clinic, following which the receptionist has asked for a doctor to make a change on the prescribing system and a new replacement prescription has been issued with the changes. This is an area of significant clinical risk, which can depend upon a patient recognising and remembering that there is a discrepancy and then bringing it to the attention of the practice. It also contributes to waste and increased cost. There has not been any system for drug monitoring, e.g. blood tests required for routine safety checking (typical examples would include checking U&Es for patients on ACE inhibitors or LFTs for patients on methotrexate). The practice has relied upon individual doctors remembering to do these tests either when seeing patients or when carrying out a medication review. The practice has not demonstrated any systematic organisation of medication reviews, appearing to rely instead on ad-‐hoc review on an opportunistic basis. Discussion with the clinical staff who have been at the practice for several years seems to reflect a concern about the difficulty of including medication review during normal consultations and may go towards explaining the low level of recorded review. This in turn will have tended to impact negatively upon any specific prescribing changes needed, including abuse / dependency risks (e.g. benzodiazepines), cost considerations (e.g. PPIs), safety concerns (e.g. Cox II inhibitors etc) and general good prescribing practice. Taken together, the absence of demonstrable systems for review and monitoring of medication represent a significantly lower standard of practice at Green Elms than that laid out in the CMH repeat prescribing policy. This will have contributed to clinical risk.
5. Management Control CMH Standards: Responsibility for management control is placed with the practice supervisor and then to a doctor or nurse in the absence of the supervisor. The policy requires that practice staff involved with the preparation of repeat prescriptions should be appropriately trained in all aspects, including protocols and responsibilities, with an emphasis on the need for accuracy. The policy addresses the need for communication, secure storage and handling, data security (including backup) and specifies annual audit of repeat prescribing. The policy describes relevant aspects of good practice in setting up and operating a repeat prescribing system, including when to involve a doctor and when to review repeat medication. Compliance at Green Elms: There was little evidence that the functions of a practice supervisor had been carried out with regard to management of the repeat prescribing system. Insofar as there has not been an identified prescribing lead in the practice, the clinical responsibilities for management of the repeat prescribing system have not rested with one doctor in an accountable way. The repeat prescribing clerk is not formally trained. There were no protocols available for review in the practice in support of the CMH policy. It appears that communication with local pharmacies has been improving, leading to a better experience for patients, involving less risk and frustration. The practice clinical system, including the prescribing record, is backed up as part of the NHS SystmOne remote infrastructure. Other points include: Stored, signed FP10 prescriptions have not been stored in a locked container. There is no evidence of annual repeat prescribing audit. Staff have been encouraged to use the ‘tasks’ messaging function of the clinical system, which ensures that queries and actions are logged with time and date, and recorded as part of the auditable patient record. Overall, Green Elms has not demonstrated management control in keeping with the standards set out in the CMH Repeat Prescribing Policy. Conclusions Review of the practice repeat prescribing systems and their management at Green Elms has confirmed that concerns about compliance with acceptable standards appear to have been justified. In all stages of the repeat prescribing process and over a period of several years, Green Elms has failed to demonstrate that it has met the standards set by CMH in its policy document. Historically, this appears largely to be due to the lack of management controls either at practice supervisor level or by named and accountable clinical staff taking a lead on prescribing.
Recommendations & Comments 1. Repeat dispensing. This would be a useful way of making the repeat process smoother and more reliable for patients. However, it is an absolute pre-‐condition that any patient whose medication is set up for repeat dispensing has been fully reviewed and meets the conditions required for a local repeat dispensing system. Until that is the case for a significant number of patients, it will not easily be possible for this to happen. 2. Repeat prescribing protocols. The practice should adopt and use brief and simple protocols for the handling of repeat prescribing, based upon the good practice already laid out in the CMH policy document. 3. New medication requests. A doctor must fully and properly review new medication requests for items not already on the repeat list. A clinical note should be made on the computerised record system by the prescriber, stating the clinical indication and rationale. 4. Signing of prescriptions - awareness. Doctors at Green Elms should be reminded that the signing of a repeat prescription is a significant responsibility and not a thoughtless exercise. The doctor / prescriber should be satisfied that systems are in place to ensure that the original decision was clinically sound, that continuing to prescribe is clinically justified and that appropriate safety mechanisms are in place to review the medication. If the doctor is not satisfied of this and / or has not put himself or herself in a position to be reassured of this, then he or she is at least jointly responsible for any harmful or adverse event which may occur. 5. Discharge / hospital clinic medication. A checking process to ensure that all discharge and clinic letters have been actively reviewed for medication changes must be put in place. Periodic audit to demonstrate that this is happening should be undertaken. 6. Drug monitoring. Patients who are taking medication that requires monitoring should be identified, using a defined search on the clinical system. This should be according to a list agreed with the local PCT prescribing advisor. Monthly recall should be done for patients due for testing either prospectively on an opportunistic basis during consultations or by calling patients to attend for tests. Periodic audit to demonstrate that this is happening should be undertaken. 7. Prescribing Clerk training. Arrangements should be made to provide training for the member of staff routinely assigned to handle repeat prescribing. 8. Secure storage. Prescriptions should be stored in a secure locked container when not being actively handled or under direct supervision. 9. Practice Prescribing Lead. The practice should appoint a permanent member of the clinical team as prescribing lead, who should ensure the use of protocols. This clinician should ensure that prescribing matters are discussed at clinical meetings as a way of sharing responsibility for this key area of improvement. 10. Medication reviews. Under the leadership of the newly appointed practice prescribing lead, Green Elms must make efforts to arrange a systematic ‘catch up’ for the bulk of outstanding medication reviews over a reasonable period of time, e.g. six months would be desirable, but greater than twelve months would probably not be acceptable. Notwithstanding the time and effort / cost that this will take, this single task can considerably reduce the burden of unnecessary medication, reduce risk, improve QOF points and form the basis for better future medicines management within the practice.
Recent Improvements Repeat prescribing was discussed with the current interim practice manager who is overseeing many changes at Green Elms. This revealed that a number of recent changes have already been made to improve the way the process works, including: • Repeat request slips – provision of a secure ‘post box’ for request slips, minimising loss and improving confidentiality. • Guidance for the prescribing clerk -‐ better handling of new medication requests. Discussion on the possibility of undertaking an NVQ related to prescribing. • Messages for tasks being relayed via the ‘tasks’ function on the clinical system, improving audit, record keeping and efficiency. Old out of date tasks have been cleared off, making current messages more relevant. • Requiring local pharmacy staff to sign confirming receipt of individual prescriptions at the point of collection.