Becoming a Prescriber

Many practitioners, especially those who are new to aesthetics, may not be prescribers, however prescribing is an additional skill you may wish to consider to augment your autonomous aesthetic practice and patient management. 

This article aims to share the considerations to make before becoming an independent prescriber. It also discusses the background to independent prescribing, benefits of being a prescriber, recent national guidance, guidance for prescribing mentors, and practical advice including top tips to consider before embarking on the V300 prescribing course.

Background

Since legislation changes in 2006, nurses and pharmacists have been permitted to independently prescribe within their area of competence. Further legal changes over the following six years allowed the prescribing of unlicensed drugs and controlled drugs (with some exceptions) within the nurse/midwife scope of competence.¹ From this successful implementation, registered professions to independently prescribe (not including supplementary prescribing) has grown and now includes: nurses, midwives, pharmacists, physiotherapists, optometrists, podiatrists and, most recently, therapeutic radiographers and advanced paramedics.²

But can all these professions prescribe in aesthetics? The Nursing and Midwifery Council (NMC) states, ‘If you hold a prescribing qualification, you must prescribe in line with the requirements of the Code and your individual scope of practice. This applies to all forms of prescribing including remote prescribing, and non-surgical medicinal products being used for cosmetic and aesthetic purposes, such as Botox’.³ 

The General Pharmaceutical Council (GPhC) advocates, ‘Pharmacist prescribers who prescribe and administer non-surgical cosmetic medicinal products must be appropriately trained, they must prescribe and administer non-surgical cosmetic medicinal products only in line with good practice guidelines, and only after there has been a physical examination of the person’.⁴

However, the regulations around prescribing in aesthetics does have diversities; the Health and Care Professions Council (HCPC) covers different professions who can prescribe (physiotherapists, optometrists, podiatrists, therapeutic radiographers and advanced paramedics), but there may be limitations for aesthetics and respective scope of practice.

There are also further restrictions on prescribing unlicensed medicines and ‘off-label’ prescribing and control drugs for certain HCPC professions.⁵ As this is still an evolving field and prescribing for selected HCPC professions is in its infancy, it is beyond the scope of this article to discuss. Those with questions should contact their regulatory body for up-to-date guidance.

It should also be noted that a number of training courses do not train all HCPC professions in medical aesthetics. 

Benefits of independent prescribing

The benefits of independent prescribing are widely documented and it has allowed the development of new roles, genuine autonomous practice, better access to medicines and has overall benefited services and patients.⁶ As an aesthetic practitioner, being able to independently prescribe prescription-only medicines (POMs) including botulinum toxins, first and second-line emergency drugs, reversal agents and anti-microbial drugs is advantageous in terms of patient management, time and autonomous holistic practice.

Undertaking the prescribing course may feel daunting, but the benefits to you personally and professionally, in my opinion, are significant. These include enhancing your consultation skills and assessments, critical thinking, clinical decision making and autonomous practitioner abilities.

New prescribing standards

New educational standards for non-medical prescribing are now available and are currently being implemented: Nursing and Midwifery Council Standards for prescribing programmes

(NMC 2018),⁷ Health and Care Professions Council Standards for Prescribing (HCPC 2019)⁶ and the General Pharmaceutical Council Education and Training Standards for Pharmacist Independent Prescribers (GPhC 2019).⁸ Due to the complexities of the NMC, HCPC, GPhC regulatory bodies and different entry criteria for prescribing, this article can only provide sign-posting guidance regarding the prescribing standards.^7,9,10 

For example, under the new NMC standards,⁹ entry onto a prescribing programme is assessed on evidence of the necessary skills, knowledge and experience. Practitioners will need to evidence they have the right skills in clinical and health assessment, diagnostics, care management, and the planning and evaluation of care. At the time of publication, all approved education institutions (AEI) are going through the revalidation process of the regulatory bodies to implement the new educational standards, which is due to be completed by September 2020.^7,9,10

Some AEIs have been through this and offer the new validated courses and entry criteria, but others are still awaiting revalidation. All programmes should be operating under the revised standards by September 2020.

The below is an example of some of the entry criteria for the new standards:^7,9,10

• Nurses and midwives at least one-year post-registration experience and in the role in which they will prescribe for at least one year
  
• Advanced paramedics at least three years’ relevant post-qualification experience in the clinical area in which they will be prescribing and have undertaken or are working towards an advanced practice qualification (as defined by Health Education England, usually an MSc)
  
• Pharmacists at least two years’ appropriate patient-orientated experience post registration, in a relevant UK practice setting
  
• Physiotherapists, podiatrists, and therapeutic radiographers must normally have been practising for at least two years at an advanced level 
  

Choosing the right AEI

Although the NMC has changed the entry criteria from three years’ post-registration experience to one-year post registration, pertinently, universities may still add extra stipulations to entry onto the V300 prescribing course for each profession to ensure governance.⁹ This may vary from each educational establishment. 

Ultimately, entry onto the V300 prescribing course is down to the educational establishment’s criteria and validated course requirements. The NMC states the selection process is often a partnership between you, your employer (if you’re employed), the AEI and their practice placement partners.⁹ Furthermore, not all AEIs offer the course to aesthetic practitioners (but many do) and some may add an extra entry criterion for the aesthetic setting. This may include, for example, being able to demonstrate Level 7 PG Cert in cosmetic/ aesthetic medicine and practice in a private healthcare environment that is regulated by the Care Quality Commission. 

However, not all AEIs have this extra requirement. Another pre-requisite for all professions onto the prescribing course may include an advanced history taking and physical assessment course. In my personal view and experience of pathway lead for the prescribing course, I would highly recommend undertaking this if you’re not already practising at this level. This is because the course will prepare you for the prescribing module and augment your autonomous practice. 

Deciding on academic levels

The next step is deciding on an academic level. In general, the NMC courses can run at both Level 6 (L6) and Level 7 (L7). Allied healthcare professionals and most pharmacist prescribing courses are only validated at L7 and advanced paramedics can only take the course at L7, so this may influence your choice.^7,10 This is only a guide so please confer with your chosen AEI as there may be some individual differences at local levels. So, have you already been awarded a degree or diploma? 

In broad terms, to study at Level 6 (degree level) you will have an advanced diploma, DipHE or equivalent. For Level 7 (Master’s level) you will have a BSc (Hons), unclassified BSc or equivalent.¹¹ The AEI may have further requirements on academic grades acquired for the corresponding award, so please review the academic criteria. If you are eligible to study at L7, I would ask, do you require the academic credits, are you on a pathway, or are you going on to complete a full MSc pathway? 

Please be aware you can use recognition of prior learning, which is normally a module of up to five years into a pathway.¹¹ If you plan to undertake a MSc in the next two years, it may be worth doing L7, so futureproof yourself and discuss this with your chosen AEI.

Another consideration is the length of the course. There is a slight variation in the academic credits for the prescribing course, ranging from 30, 40 or 60 credits depending on the location. In addition, obviously L7 will have a slightly higher marking grade to pass. Still unsure? Ultimately the prescribing qualification on the register is the same if you undertake the L6 or L7. So, if you are eligible and you need the academic credits then do L7, if not and you just require the prescribing qualification (assuming is it offered at this level for your profession) then you could complete the course at L6.

Designated prescribing practitioners (DPPs)

Alongside the new standards there is updated guidance for those taking on the supervisory and assessing role for prescribing students. Regulatory changes mean that experienced non-medical prescribers can become responsible for a trainee prescriber’s period of learning in practice in a similar way to Designated Medical Practitioners (DMP).¹²

In this guidance, the Royal Pharmaceutical Society (RPS) refers to those fulfilling this new role collectively as Designated Prescribing Practitioners (DPPs).¹² Terminology generally used by each of the bodies is as follows:

• The HCPC uses the term Practice Educator
  
• The NMC standards describe two roles key to learning in practice: Practice Assessor and Practice Supervisor (this must be two different practitioners unless exceptional circumstances apply⁹)
  
• The GPhC uses the term Designated Prescribing Practitioner (DPP) as the title for this role
  

All three regulators have slightly different requirements which need to be considered. For eligibility of the DPP role, please also review the AEI criteria. 

Assessments

Assessments for the prescribing course will vary depending on the individual validated AEI programme, however, this could include case studies, clinical management plans (for supplementary prescribing), practice assessments, clinical decision making, patient reflections or an essay. The NMC standards require passing a pharmacology exam with a minimum score of 80%, and passing a numeracy assessment related to prescribing and calculation of medicines (this must be passed with a score of 100%).⁹ 

A portfolio of supervised prescribing hours and evidence of mapping to the ‘RPS Competency Framework for all Prescribers’, is also generally required.¹¹ All the new prescribing programmes^7,9,10 will deliver outcomes which meet the ‘RPS Competency Framework for all Prescribers’.¹¹ This framework is supported by all three of the regulatory bodies. 

Moving forward

This article has aimed to provided factual and sign-posting information and suggestions regarding the independent prescribing course. Importantly, read the appropriate regulatory guidance. Research the right AEI for you; not all deliver the prescribing course for each of the professions and some do not offer the course to independent aesthetic practitioners, but many do, so be prepared to travel if necessary. Ensure you can complete all the clinical hours and have a dedicated DPP, practice supervisor/assessor or educator.

Finally, the key to success here is to plan ahead, have good time management and dedication. It maybe time consuming, even stressful at times, but it’s doable. You can do it, and it will be the best course you will do in terms of patient management and knowledge, professionally and personally, and I promise you won’t regret it.

Top tips

This may feel like a lot of information, so here are some top tips to help.

• Read the regulatory guidance from each body
  
• Do your homework and research the AEI criteria
  
• Ensure you can attend all the study days and complete the clinical hours
  
• Enquire about a DPP (as discussed previously) – can they offer you varied dedicated clinical supervision and sign off on your hours? Set regular meetings to meet your outcomes. Ensure they are familiar with the sign off documents you’ll be provided with. Ensure you both know the hand-in dates for completion and work towards this
  
• Pharmacology – if this is an area in which you have less knowledge, I would suggest reading and learning before the course. For non-pharmacists, my book recommendations to start with basic pharmacology are referenced below at the end^12,13
  
• Essay writing if this is relevant – you will get academic support and library support but give yourself enough time to prepare the essay or case study and to get an essay draft reviewed
  
• IT – if you have not already, ensure you have access to a reliable computer or laptop
  
• Collect any examples of patient reflections and interesting topics or evidence base practice
  
• Calculations – if this is an area of weakness I would suggest practising daily, there are many online resources that can help too. The pressure to attain 100% pass mark can put more stress on you; in my experience, I have had prescribing students who felt they couldn’t achieve this or worried they could not pass the course. These students were supported and encouraged, they worked so hard to achieve their goal and ultimately passed with the highest grades.
  
• Remember that this course is achievable with time and preparation – you don’t have to be a superhero, but be organised 
  

Note: the above is guidance only and is understood to be correct at the time of writing. Criteria and requirements as stated are subject to change.