Guidelines covering the issue of the remote prescribing of drugs are provided by the MHRA, the GMC and the NMC, however until recently specific advice concerning the use of remote prescribing in the aesthetic industry, particularly in relation to the provision of botulinum toxins (e.g., Botox®, Azzalure®, Xeomin®) did not exist.
The NMC Standards for Medicines Management were issued in 2007. All nurses in all specialities are required to adhere to these Standards and the NMC notes that there can be no exceptions made for aesthetic nurses. It must be understood by nurses that Standards are law.
Then in 2009 the NMC recognised that nurses working in aesthetic nursing needed some clarification on matters and so introduced advice for its members on the subject of injectable cosmetic treatments. Guidance and advice directly supports the NMC Standards and states:
“remote prescriptions or directions to administer should only be used in exceptional circumstances and not as a routine means to administer injectable cosmetic medicinal products”
So what does this mean for nurses who are using remote prescribing services?
Put simply, it means that any nurse following a remotely issued direction to administer an injectable cosmetic drug is going against their governing body's advice. All nurses are accountable to the NMC for their actions and must practice within its guidelines. Therefore if a nurse chooses to go against this advice then they may be asked to explain their actions to the NMC in a fitness to practice hearing.
So, you might ask what should I do if I am already using a remote prescribing service?
Essentially those nurses already using a remote prescribing service now need to think about how they can work within the NMC guidelines with their prescribing doctor, which may mean that he or she visits their clinic to see their patients and to prescribe for them in person.
Nurses may also wish to team up with a nurse prescriber in their area, a so called “prescribing buddy” who can prescribe for their patients and authorise them to administer under their patient specific direction. A database of prescribing buddies is currently being compiled.
Alternatively it may be time to consider undertaking a V300 prescribing course or their own.
As well as the broad issue of remote prescribing, the issue of working from a written or verbal direction has also been a major cause for concern, consideration and confusion amongst nurses. A verbal order is not acceptable under NMC standards, even if the doctor advises the nurse on the dose and dilution of the toxin product, (this is not often the case) the direction must be in writing and signed.
Were a nurse to follow a verbal direction only, without a written direction, this could result in a fitness to practise trial, if it were reported to the NMC, which may result in the nurse being removed from the NMC register. How many nurses are aware of this?
To help clarify matters a meeting was held on 20th May 2010 under Chatham House rules with Rebecca Cheadle from the NMC, who was available to answer questions from nurses and discuss the issue of remote prescribing without recrimination.
According to Mai Bentley, Director of Training at Intraderm Ltd and British Association of Cosmetic Nurses (BACN) Member, the most important message to come out of the meeting was the clarification that if a nurse administers botulinum toxin, lignocaine or other prescribable drugs without a written and signed direction in front of him or her, this is against NMC standards and therefore unlawful.
“Nurses need to take more responsibility to keep themselves updated and aware of legislation. Many nurses at the meeting on 20th May with the NMC were angry to find that information given to them by some medical colleagues was incorrect and that they were indeed working illegally.”; notes Mai.
Thus in order to administer botulinum toxin products to their patients and stay within NMC guidance, aesthetic nurses should not be using remote prescribing services and should only be treating when in possession of a written and signed direction from a prescriber who has actually seen their patient in person.
More detailed information will be available on this subject in the June edition of The Consulting Room™ Gold Members newsletter.