Our response to the Royal Pharmaceutical Society competency framework for all prescribers consultation

We responded to a Royal Pharmaceutical Society consultation on a competency framework for all prescribers (May 2021).

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Summary 

We responded to a Royal Pharmaceutical Society consultation on a competency framework for all prescribers. We support this framework as it allows for a more consistent and unified approach to prescribing so that patients receive high quality, safe, effective, and consistent care. The document provides clear direction for safe and effective prescribing practice that could be used to support IP optometrists’ CPD. In particular, to help identify areas/gaps in learning to address through self-directed learning and appraisal. However, we are concerned that the GOC may not adopt the framework so it may not be used as a basis for developing IP education programmes, placements, assessments, or CPD resources. Read more about the consultation.

 

Q1. Is the scope and purpose of the competency framework for all prescribers clear? If no, please provide further comments.

NO

Further comments:

Some guidance on how to contextualise the different levels of expertise would be useful, as the dependence on the framework will vary considerably between a newly qualified IP and an experienced IP.

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Q2. Is the framework sufficiently generic to apply to prescribers from your professional background? If no, what needs modification?

YES

Further comments:

The competency framework applies to all prescribing professions as the competencies described are common to and underpin the act of prescribing medicines. This allows for a more consistent and unified approach to prescribing so that patients receive high quality, safe, effective, and consistent care and are aware of the standards expected of prescribers.

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Q6. Is each supporting statement unique and do they describe a clear outcome? If no, please provide further comments.

NO

Further comments:

1.9: Some optometrists do not have immediate access to a patient’s previous eye care or medical records to understand the patient’s full medical and eye care history as most eye conditions that require therapeutic intervention are acute. Thus while they may become “available” after consent obtained, this may not be immediate or accessible to provide appropriate care in that consultation. Some clarity would be useful to reassure prescribers – suggested change: “Where possible, accesses and interprets all available and relevant patient records to ensure knowledge of the patient’s management to date.”

1.13: A particular prescriber may not be competent to review adherence or determine the effectiveness of all the patient’s medications, as they may be prescribed by another professional of different healthcare discipline and/or outside of the scope of their practice. Suggested change: “Where appropriate, reviews adherence to and effectiveness of current medicines.”

3.4: Adherence is a very useful term to assess compliance with taking a medication, but it may imply a paternalistic approach where the prescriber expects a treatment regimen to be followed without reference to the patient. Thus, the term “concordance” may be more helpful as it reflects the agreement between the prescriber and patient to follow a treatment plan in order to make the best use of the medication and improve compliance. This reflects a more patient centred approach where prescribers work alongside their patients in partnership to improve healthcare outcomes.

4.11: An “off-label” medicine should be prescribed with the same caveat as for “unlicensed” medicines; such that the prescriber must be satisfied that an alternative licensed medicine would not meet the patient’s needs.

4.14: Should include reference to ensuring appropriate consent to sharing patient information for the purposes of direct care. Although explicit consent is not required for these purposes, the prescriber must ensure it is valid. Sharing of data/patient information must also comply with GDPR legislation, so must be secure with information governance procedures in place.

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Q7. Is there any repetition or overlap with the supporting statements? If yes, please provide further comments.

YES

Further comments:

6.1 and 6.2 appear very similar – maintaining a plan for “reviewing the patient’s treatment” would necessitate the need to monitor said treatment’s effectiveness and potential for unwanted side effects. Suggest this to be merged, together with an amendment to Box 6 further information section.

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Q9. Is the information in the “further information” sections clear and fit for purpose? If no, please provide further comments.

NO

Further comments:

For competency 6.4, it would be useful to provide an example in “Box 6”. Suggested text: “6.4 – reporting systems includes following established clinical governance procedures and the MHRA Yellow Card scheme.”

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Q10. How might you/your organisation use the framework once it is published?

This framework may form the competency basis for future iterations of the therapeutics common final assessment in independent prescribing for optometrists and clinical placement (although this is dependent on the profession’s regulator, the General Optical Council, adopting the framework).

It may also be used to inform the development of CPD materials.

As clinicians, the document provides clear direction for safe and effective prescribing practice that can be consulted to support their continuing professional development. In particular, to help identify areas/gaps in learning to address through self-directed learning and appraisal. It may finally be used as a structure to evidence competency in prescribing as part of a portfolio to encourage reflective practice.

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Q11. How could you/your organisation help to promote the framework once it is published?

We could promote the framework through our regular communication channels, e.g. website, newsletter, social media platforms and through a potential Members briefing to highlight the College’s role in collaborating with the RPS and other prescribing professions to develop the updated framework and provide a link to the website.

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Q12. What might be the barriers to using this framework in practice?

The General Optical Council (GOC) may not adopt the framework so it could not then be used as a basis for developing IP education programmes, placements, assessments, or continuing professional development resources. The General Optical Council (GOC) have indicated that any adoption of the framework will not apply to its current Independent Prescribing handbook and will only be considered as part of its current ongoing Education Strategic Review (ESR).

The framework may not be utilised fully with respect to 9.6 as currently IP optometrists are not permitted by the GOC to become designated prescribing practitioners as stated in the GOC Handbook for Optometry Specialist Registration in Therapeutic Prescribing, July 2008 (3.2 Practice-based Learning).

While many IP optometrists work in hospital settings and work part of multidisciplinary team, others may work alone in community settings – the need to work collaboratively with other healthcare teams/professionals may be hindered by lack of access to patient records and lack of established and secure communication processes (e.g. electronic patient records and referral systems) 

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Q13. Are there any supporting references or resources that you think should be highlighted to support implementation of the framework?

In information box 7, it would be very useful to highlight/refer to the “high level principles for good practice in remote consultations and prescribing” for competency 7.3; this is co-authored and endorsed document by a range of healthcare regulators (GMC, GDC, GOC, GPC, NMC, HCPC. PSNI) to show what good remote prescribing looks like: High level principles for good practice in remote consultations and prescribing – General Optical Council Standards

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Submitted: May 2021

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