Can bank and agency staff operate under an organisation’s Patient Group Directions (PGDs)?

Organisations who utilise bank or agency staff may consider allowing these staff members to operate under PGDs to maintain service provision.

Whilst there is nothing in PGD legislation that would prevent agency or bank nurses from being authorised to use PGDs there are governance issues which need to be considered.

For the purposes of this document agency staff are defined as those who do not have any direct contract of employment with the organisation whilst bank staff are defined as those employed directly by the organisation to work as part of the organisation’s staff bank.

Agency staff

  • Qualification and training requirements
    • The same training and governance requirements would need to be in place for both the organisation’s employees and agency staff.
  • Assessment of competency and authorisation to use the PGD
    • PGDs should only be used once the healthcare professional (HCP) has been assessed as competent in line with the local process and named to work under each relevant PGD.
    • The organisation would need to be able to demonstrate that they had assessed the HCP as being competent to operate under the PGD in line with local processes, to the same standard as for directly employed HCPs.
    • It maybe complex when using an agency to ensure the appropriate governance arrangements are always undertaken and as such an agreed local process should be in place and audited regularly to ensure it is followed.
    • Given the above, it is potentially challenging for an organisation to be assured that only trained competent staff employed by an agency are supplying/administering medications under the authorisation of their organisation’s PGDs.
  • Vicarious liability
    • The need for additional insurance would be a contractual discussion between the provider and the agency providing the practitioner and how the practitioner is supported to operate within their specific skill base and not be expected to practice or operate outside of this.

Bank Staff

It is possible to utilise and authorise HCPs working for an organisation’s staff bank to practice under PGDs if the bank staff member is able to demonstrate the required competency and training and can be assessed in relation to the role they are going to fulfil.  This may be in the area they are transiently working in or a regular working environment.

If the staff member has evidence of up to date relevant training and are deemed competent in line with local processes then they can be considered for authorisation to operate under a PGD in the same manner as other HCPs employed by the organisation working under the PGD.