Dental mythbuster 36: Security of blank prescription forms

Our inspectors will consider the use and disposal of prescriptions when they review 'is the practice safe?'

This relates to:

• Regulation 12 (Safe care and treatment)
• Regulation 17 (Good governance)

and key line of enquiry (KLOEs):

• S4: How does the provider ensure the proper and safe use of medicines, where the service is responsible?

Background

Practices need to have systems in place to ensure prescriptions are produced, signed and stamped in accordance with the current regulations. These are:

• Schedule 6 of the NHS (Pharmaceutical and Local Pharmaceutical Services) Regulations 2013 and
• the associated paragraph 39(3) of Schedule 6 to the GMS Regulations.

National guidance

The Dispensing Doctors Association (DDA) has produced updated guidance for dispensing practices. The guidance is clear that prescriptions should be signed before they are dispensed.

The NHS Counter Fraud Authority has published guidance for the management and control of prescription forms: A guide for prescribers and health organisations (March 2018).

This guidance

• supports providers, both NHS and private, authorised by their commissioner to order prescriptions
• helps providers develop local systems to ensure the security of prescription forms against theft and misuse
• applies to blank computer prescription forms and handwritten pads.

Organisations holding stocks of prescription forms are responsible for their management and use by:

• preventing theft and misuse through secure storage
• developing a policy outlining roles and responsibilities
• developing local protocols outlining actions to take in the case of loss, theft or missing prescription forms/paper
• controlling and recording prescription form movement, including recording serial numbers.

What is the problem?

A prescription form is an asset that has a financial value. It is, in effect, a blank cheque open to potential misuse. Theft of prescription forms and their resulting fraudulent misuse is a serious concern. It can lead to loss of valuable NHS resources and potentially result in serious harm. Forms can be used to illegally obtain controlled drugs (CDs) and other medicines. This can be for illegitimate personal use or to sell on.

Fraud or thefts are not always complex or on a large scale; single forms can be stolen from the prescriber’s bag, car, home or desk.

Methods to obtain blank forms include tactics to distract busy staff with what appear to be genuine patient requests. The offender gains access to, or is left in, a consulting room and steals blank prescription paper from an unattended computer. They scan a genuine prescription and print out copies on the stolen forms. These can be very difficult to detect.

When we inspect

We expect all prescribers in the practice (including locums) and all staff involved in the management of prescription forms to be able to tell us how the practice manages and secures blank prescription forms and paper. This should be in line with national guidance unless the practice can justify, with risk assessment and mitigation, why this is not the case.

We also expect:

• Clear and unambiguous records of prescription stationery stock received.
• Clear arrangements for the arrival of prescription form stock. This should include a pre-determined date of arrival where possible, so a missed delivery can be followed up quickly.
• Prescription form stock checked on delivery. Barcodes recorded, checked against the delivery note, and stock stored securely, at least in a locked cabinet within a lockable room or area as soon as possible
• Access to forms restricted to authorised individuals.
• Records kept of prescription forms that are:
  • returned to stock
  • destroyed, and the reasons for destruction.
• Clear storage system for prescribers using individualised forms:
  • kept in a locked space and not with patients’ notes
  • the serial number of the first remaining form is made at the end of each patient session.
• Measures in place to keep forms secure. For example:
  • only authorised individuals have access to the lockable room or area where prescription form stocks are kept.
• Regular stock checks undertaken on prescription forms. Where possible, separate duties of ordering, receiving and stock checking the prescription forms.
• A system for storing prescription forms when seeing patients outside practice premises, for example, on home visits. It is advisable to take a limited number of forms and record serial numbers.
• Staff know what to do if they suspect prescription forms have gone missing.

The NHS Counter Fraud Authority guidance also includes information on:

• destroying spoiled or duplicate prescriptions
• prescriptions by post
• transferring prescriptions from one site to another (for example to a branch surgery)
• locum access to prescriptions
• alerts, investigations and sanctions
• audit.