NMC Clarifies Legal Guidelines For Nurses Using Remote Prescribing Services

Posted on the 08 June 2010 at 13:23

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.

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Blog Comment(s) [7]

Hi, I really enjoyed reading your article on botox prescribing issues for nurses. I have certification to give botox and fillers but have not started practising due to uncertainty re: who to approach re: prescriptions. Where can I find these " prescribing buddies" or who is recommended to use i.e.clinic?, recommended GP? in order for me to move forwards with in my professional code of conduct and standards.
Kind regards


Claire - we would recommend that you contact the British Association of Cosmetic Nurses for help and advice in this matter. They also have their inaugural conference this September which may be worth attending. You can find out more about them at their website.

Lorna Jackson | http://www.consultingroom.com

Hi there,
So, just to clarify, if I pass the Nurse Prescribing Module at Level 3 does this mean I can prescribe injectible dermal fillers and Botox without using a prescribing buddy?


Hi there, if you undertake the V300 Independent and Supplementary Prescribing Course for nurses at any UK university and pass the examinations then your NMC registration will be altered to show your prescribing qualification of N.I.P. or Nurse Independent Prescriber. This course is taught at degree or masters level. Following successful completion of this course you can indeed prescribe Botox and dermal fillers for individual named patients. You can also receive the drugs and store them for that named patient until you decide to administer them. (What you cannot do is to order wholesale like a doctor can or to store stocks of drugs unless you belong to the same legal entity as a doctor) Therefore on a day to day normal basis you can be totally independent and prescribe your own drugs without a prescribing buddy. Just check with the university that the prescribing module that you refer to is indeed the V300 and not just a limited prescribing module that district nurses etc have used in the past as this would not allow you to prescribe Botox etc. Most universities across the U.K. will offer a V300 as well as the university that I teach at and we have recently just helped to write an article aimed at educating the wider nursing population about aesthetic nursing. We hope that this will encourage more universities to accept more aesthetic nurses onto V300 courses.

Mai Bentley


I would be very grateful if you could provide me information on becomming qualified to administrating Botox. I am a RGN.

Any help or advice you could offer would be helpful.

Kind regards.


Donna Brown

Hi Lorna, i am a newly qualified nurse and am training to administer azzalure and dermal fillers near the end of this month. The reading material provided the training company states that nurses can buy in stock of azzalure and that it can be administered to any person who qualified following assessment and consultation. Is this true?


Hi Tony, I would refer you to the guidance on the MHRA website which you can compare with the exact wording detailed in the literature supplied to you by the training course company.

Generally speaking a Nurse or Independent Nurse Prescriber cannot buy in stock of a botulinum toxin brand. The only way advanced stock is permitted is for nurses working within a clinic or hospital which provides the product for him/her through internal processes; however no administration can be done without patient specific directions from the prescriber.

Please read this:
Frequently asked questions: Supply and administration of Botox?, Vistabel?, Dysport? and other injectable medicines outside their licensed medicinal uses such as in cosmetic procedures

Lorna Jackson | http://www.consultingroom.com