Correspondence

Circular 027/2015: Approved mandatory requisition form and Home Office approved wording

Published 9 November 2015

1. This circular draws attention to the introduction of a requisition (order) form, approved by the Secretary of State, for Schedule 2 and 3 controlled drugs which must be used by health and veterinary care professionals in the community. The circular also draws attention to a set of new Home Office approved wording for the instalment prescribing of controlled drugs.

2. The requirement to use a mandatory requisition form was introduced under Statutory Instrument (SI), S.I. 2015/ 891 which came into force at 00:01 on 1 June 2015. The commencement of provisions relating to the use of the form was delayed until 30 November 2015.

3. The SI together with an explanatory memorandum can be found at http://www.legislation.gov.uk. The SI is also published by The Stationery Office. Telephone orders/General enquiries 0870 600 5522 or order online. A copy of this circular can be found at:

1. Legislative Background

1. Whilst the Home Office has legislative responsibilities for the Misuse of Drugs Act 1971 and its associated regulations, the policy area is shared with the Department of Health (DH). The legislative document (S.I 2015/891) and this circular have been drawn up in consultation with them. The legislative framework for controlled drugs requisitions (orders) and prescriptions are set out in Regulations 14 and 15 of the 2001 Regulations respectively.

2. Policy Context

2.1 Mandatory Requisition Form

1. The Shipman Inquiry recommended in its Fourth Report that the purchase of all stocks of controlled drugs by healthcare professionals should follow a procedure that is capable of being monitored. The recommendation further highlighted the need for a standardised requisition form, similar to prescription forms, when individual healthcare professionals requisition controlled drugs, and for the form to be sent to the NHS Business Services Authority so that purchases of controlled drugs (Schedule 2 and 3) by individual healthcare professionals in the community can be monitored.

2. The then Government agreed with the recommendation in its response to the Fourth Report, subject to further work on feasibility and cost. In 2006, the DH issued a recommended standard form with guidance to be used when healthcare professionals requisitioned controlled drugs. This requisition form is compliant with the data requirements under the 2001 Regulations but its use was not made mandatory. In its 2009 Annual report, the Care Quality Commission recommended that the DH should revisit the requisition regulations and guidance to ensure the purchase of controlled drugs by all individual doctors and healthcare professionals are identified and captured in line with the original Shipman recommendation. Data from the NHS Prescription Pricing Department in 2011 indicated that the majority (above 80%) of requisition forms received were compliant with the DH guidance and used the DH recommended form. The Home Office and the DH therefore considered whether it was necessary to legislate to make it mandatory to use a specific form in order to ensure that the around 20% of professionals who were not using the recommended form were mandated to use the new form.

3. These proposals were consulted on in 2011 and as a result of the outcome of the consultation legislative changes were implemented to introduce a new mandatory form for requisitions of Schedule 2 and 3 controlled drugs. The use of the new mandatory form takes effect on 30 November 2015. The summary of responses to the 2011 consultation is available

3. New Home Office approved Wording for instalment prescribing

1. The current Home Office approved wording for instalment prescribing was issued to assist pharmacy teams and dispensers (under the supervision of the responsible pharmacist) in determining the precise intention of a prescriber on prescriptions to be dispensed in instalments. Over the years, there have been concerns raised over their lack of flexibility, especially around the holiday season and their length which causes problems due to the limited space on prescription forms. These shortcomings have on the rare occasion been reported to impact on patient care and created additional burdens for prescribers. As a result in 2014, the Royal Pharmaceutical Society put forward proposals to review the approved wording to ensure it continued to assist instalment prescribing but was flexible enough to ensure patient care was not compromised. These proposals were fully considered by the Home Office, the Department of Health and the Orange Guidelines Group leading to an agreed set of approved wording shorter in length and more flexible than the current wording.

2. As the Home Office approved wording is used mainly for Schedule 2 and 3 controlled drugs prescribed for dispensing on instalments basis, it is expected that the shorter length of the new agreed wording and the flexibility it provides will also make its use in electronic prescriptions easier under the NHS Electronic Prescription Service.

4. Specific Changes

4.1 Introduction of mandatory requisition form – England only

1. The new approved requisition form, in electronic format, is made available online. The requirement to use the mandatory form applies to the professionals listed at regulation 14(4) of the 2001 Regulations, which now include paramedics and the person in charge or acting person in charge of an organisation providing ambulance services. The form must be used only when stocks of the relevant controlled drugs are to be obtained in the community, including from wholesalers but outside settings such as hospitals where supply to wards are governed by different provisions. From 1 June 2015, hospices and prisons are exempt from the requisition requirements under the 2001 Regulations, and are not required to use the mandatory form when ordering the relevant controlled drugs. The scope of the form includes pharmacy to pharmacy transfer of controlled drugs stocks.

2. Professionals can complete the form online or download onto local drives prior to the form being completed, printed and signed in wet ink. However, the form is designed to reset anytime it is saved with added data to prevent confidential details of requisitioners falling into the wrong hands. The form also has an in-built security mechanism which generates a unique code when completed electronically. This facility is not available for forms that are printed blank. It is expected that this facility will in the future further assist the NHS Business Services Authority in its data collection and CD Accountable Officers in their monitoring role.

3. These changes and the security features highlighted above do not impact on the responsibility placed on suppliers under the 2001 Regulations to ensure that a person requisitioning controlled drugs is either authorised under the 2001 Regulations, or has a Home Office licence, which entitles them to possess the relevant controlled drugs.

5. New Home Office approved wording for instalment prescribing

1. The new Home Office approved wording for instalment prescribing is provided at Annex A. The new wording can be used immediately and can also be mixed and matched to express the prescriber’s intention. However, as usual where this intention is not clear it may be necessary, subject to the professional judgment of pharmacy teams and dispensers, to contact the prescriber.

2. The Home Office recognises that it will take some time for the introduction of the new wording to be implemented via prescribing software systems. It is therefore not the intention that prescriptions which have the old wording should be immediately rejected by pharmacy teams and dispensers. All legal prescriptions which incorporate the old wording and clearly establishes the intentions of the prescriber should be accepted and dispensed as is currently the case, unless in the professional judgment of pharmacy teams and dispensers, there are reasons why these prescriptions should not be accepted. Prescribers must therefore use either the new wording or the old wording but not a combination of both or an amended version of the old wording.

3. The expectation is that prescribers will take steps to move from using the old approved wording to the new set of approved wording in the coming months. The Home Office will review the position in three to six months.

6. Application to England, Wales and Scotland

1. The changes described in this circular apply to England, Wales and Scotland. However, Wales and Scotland have their own approved controlled drug requisition forms which professionals should continue to use in both countries. Northern Ireland will introduce its own changes separately where necessary. The contact there is:

Seamus Camplisson
Health Protection Branch
Department of Health, Social Services and Public Health
22 Castle Buildings,
Stormont
Belfast
BT4 3SQ

Contact Seamus.Camplisson@dhsspsni.gsi.gov.uk

7. Annex A – New Home Office approved wording

1. Please dispense instalments due on pharmacy closed days on a prior suitable day.
2. If an instalment’s collection day has been missed, please still dispense the amount due for any remaining day(s) of that instalment.
3. Consult the prescriber if 3 or more consecutive days of a prescription have been missed.
4. Supervise consumption on collection days.
5. Dispense daily doses in separate containers.