Delegation of supply or administration of medicines using a Patient Group Direction

Jo Jenkins, Specialist Pharmacist (Patient Group Directions) SPS Medicines Use and Safety Division Published

Summary

This page explains why delegation of supply or administration under a PGD is not permitted.  A set of common scenarios are given to guide and support users based on frequently asked questions.

National guidance on delegation

NICE guidance

NICE MPG 2 Patient Group Directions 2017 states: When practising under a PGD, health professionals should not delegate their responsibility.

MHRA guidance

The Medicines and Healthcare Regulatory Agency (MHRA) has confirmed (2021) that:

  • Administration of an injectable medicine must not be delegated under a PGD. Where a supply of an injectable medicine is made under a PGD, there must be a legal mechanism for subsequent administration if it is not to be self-administered; for example, where a medicine is supplied under a PGD but is administered for the purpose of saving life in an emergency as listed in Human Medicines Regulations Schedule 19, Regulation 238
  • If the PGD only covers supply of a non-injectable medicine by the health professional named in it, then it can be given to the patient for self-administration or for administration by another person. The law requires that administration of the supplied medicine is in accordance with the PGD and so the PGD should specify that the medicine is supplied for subsequent administration and it is labelled appropriately.

Scenarios

The following scenarios provide examples to help interpret the law into practice.

Administration by relatives or carers

This scenario covers administration of a medicine using a PGD to a patient by a third-party, relative or carer.

  • Injectable medicines: Relatives and carers cannot administer injectable medicines supplied under a PGD.  It is not within the law to inject prescription only medicines to another person unless you are a prescriber or acting under the directions of a prescriber. If an injectable medicine needs to be supplied for a parent/carer or other health practitioner to administer, a prescription or Patient Specific Direction from a prescriber will be required to authorise the administration.
  • Other medicines: Relatives and carers can administer non-injectable medicines supplied under a PGD.  The law does not restrict who may administer non-injectable medicines supplied under a PGD (e.g. a “to take home” (TTO) pack for a non-injectable medicine) providing they are administered with the individual’s consent.  The PGD should contain details of the relevant advice that must be provided to the individual and/or their relative/carer to ensure that the medicine is administered as intended by the practitioner making the supply. Medicines that are supplied for subsequent administration outside the clinic setting must be appropriately labelled and contain a product information leaflet.

Medicine supplied under a PGD for subsequent administration by a healthcare worker in a community environment

This scenario details how/if a medicine supplied under a PGD can be subsequently administered by a healthcare worker working for the same, or different organisation to the one employing the person making the supply (e.g. community nurse supplied under a PGD for subsequent administration by a care home worker).

  • Injectable medicines:  An injectable medicine cannot be supplied under a PGD for another person to administer.  It is not within the law to inject prescription only medicines to another person unless you are a prescriber or acting under the directions of a prescriber. If an injectable medicine needs to be supplied for a parent/carer or other health practitioner to administer, a prescription or Patient Specific Direction from a prescriber will be required to authorise the administration.
  • Non-injectable medicines:  Where the PGD clearly covers supply only by the healthcare professional of a non-injectable medicine, then it can be given to the individual for self-administration or for administration by another person.  However, the PGD should specify that the medicine is supplied for subsequent administration. The PGD should also contain details of the relevant advice that must be provided to the individual and/or their relative/carer.
  • Care worker location:  In the scenario (where a non-injectable medicine is supplied under PGD for administration within another care setting) the organisation providing the care must decide who may be authorised to administer medicines within their local medicines policies and governance arrangements.  Those authorised by their employing organisation to subsequently administer medicines supplied under the PGD (e.g. care home workers) must be appropriately trained and competent to do so. NICE SC1 Managing Medicines in Care Homes 2014 gives further information on managing medicines in care homes.

Supplying low molecular weight heparin (LMWH) injection to individuals in a pre-operative assessment clinic

This scenario details the position when LMWH is supplied under a PGD for subsequent self-administration.

A PGD is suitable here, but only if the individual will self-administer the injections.

It is not within the law to inject prescription only medicines to another person unless you are a prescriber or acting under the directions of a prescriber. If an injectable medicine needs to be supplied for a individual/carer or other health practitioner to administer, a prescription or Patient Specific Direction from a prescriber will be required to authorise the administration.

Practicing injection technique under a PGD

This scenario relates to a student nurse practicing their injection technique by administering an injection supplied by a healthcare professional under a PGD.

A PGD is not suitable here.  This scenario represents delegation by the registered, authorised health professional to the student nurse. Delegation is not allowed under a PGD under any circumstance.

In addition, NICE MPG 2 Patient Group Directions 2017 2017 states that PGDs are not suitable for health professionals who are undergoing relevant training, for example, for administering intramuscular injections.

We’ve also produced some guidance on this issue

Preparing and posting a medicine supplied under a PGD

This scenario details a clinic administrator posting a supply of bowel cleansing medication to an individual after clinical assessment by a nurse operating under a PGD.

A PGD is not suitable here, since this is delegation of supply and is not allowed.  The healthcare professional undertaking the clinical assessment is also required to make the supply to the individual (see advice on remote consultations for further advice on posting of medications supplied under a PGD).

Supply of a medicine by a pharmacy technician or assistant

The scenario here is a pharmacist in a community pharmacy instructing a pharmacy assistant to supply varenicline to an individual after the pharmacist has clinically assessed the individual under a PGD.

A PGD is not suitable here, since this is delegation of supply and is not allowed.

In this scenario, the pharmacist must assess the client and must also supply the medicine according to the PGD. However the assistant or technician could gather background information from the patient to support the pharmacist’s assessment.  They could also provide additional information to the individual. However an authorised registered healthcare professional should, when supplying under a PGD, personally make the supply of the patient pack to the patient at the time of consultation – the supply cannot be delegated to another person following assessment by the authorised healthcare professional.

Medicine supplied under a PGD for subsequent administration by a healthcare worker in a prison environment

This scenario relates to a registered nurse working in a prison who supplied a medicine using a PGD with administration undertaken subsequently by another healthcare professional.

  • Injectable medicines: An injectable medicine cannot be supplied under a PGD for another person to administer.  It is not within the law to inject prescription only medicines to another person unless you are a prescriber or acting under the directions of a prescriber. If an injectable medicine needs to be supplied for a parent/carer or other health practitioner to administer, a prescription or Patient Specific Direction from a prescriber will be required to authorise the administration.
  • Non-injectable medicines:  If the medicine supplied under the PGD is a take-away pack for a non-parenteral (non-injectable) medicine, it is within the law for the PGD to be used for “supply only”. The PGD should specify that the medicine is supplied for subsequent administration. Another person may administer a non-injectable medicine as necessary.

Clinical assessment by a nurse under a PGD with supply via community pharmacy

This scenario involves a nurse assessing an individual under a PGD who then directs the individual to a community pharmacy to obtain the supply (e.g. using a voucher).

A PGD is not suitable here, since this is delegation of supply and is not allowed.

The nurse may direct a patient to a pharmacist to obtain a recommended product but any decision to supply would only be made once the supplying pharmacist had independently carried out an assessment of the patient and is satisfied that an appropriate medicine is being supplied.

Supply of the nasal live attenuated influenza vaccine (LAIV) to a child for subsequent administration by a healthcare support worker

This scenario details the administration of the nasal ‘flu vaccine by a HCSW after it has been supplied to a child by a nurse working under a PGD.

A PGD is suitable here, provided the PGD states supply for subsequent administration. LAIV is a non-injectable medicine. In addition, guidance has been provided (by whom and when) that LAIV does not need to be labelled if it is administered to the individual before they leave the clinic setting.

Medicine supplied under a PGD for subsequent administration by a healthcare worker in a inpatient hospital environment

In this scenario a nurse within a hospital uses a PGD to supply a medication which will then be administered by another healthcare professional.

If the PGD clearly only covers supply of a non-injectable medicine by the health professional named in it, then it can be supplied to the patient for self-administration or for administration by another person; however, this should not be routine practice but reserved for use where it is locally deemed necessary to improve patient care or safety.

The law requires that administration of the supplied medicine is in accordance with the PGD and so the PGD should specify that the medicine is supplied for subsequent administration.

The majority of clinical care should be provided on an individual, patient-specific basis and PGDs reserved for those limited situations where this offers an advantage for patient care without compromising patient safety.  In all environments prescribing on an individual patient basis by medical and non-medical prescribers should be undertaken in preference to PGD use.

If used a PGD should contain details of the relevant advice that must be provided to the individual and/or their relative/carer including administration details.  All relevant documentation must be completed by the person making the supply under the PGD including any clinical records in line with local policy as must associated administration records.

Those authorised by their employing organisation to subsequently administer medicines supplied under the PGD (e.g. nurse or healthcare support worker) must be appropriately trained and competent to do so.

An example of this in practice is the supply of MRSA decolonisation products under a PGD by an infection control specialist nurse in an inpatient environment to prevent a delay in starting treatment although other examples may exist.

Delegation of PGD authorisation to another healthcare professional

This scenario relates to a pharmacist delegating their authorised use a of a PGD (i.e. one they are authorised to operate under) to another pharmacist, such as a locum, on their day off.

A PGD is not suitable here. Only the qualified professional who has been authorised to operate under a PGD can do so. They cannot delegate this responsibility to another person.

In this scenario, the locum would also need to be authorised to operate under the PGD.

Remote assessment and supply under a PGD

This scenario concerns the remote assessment of an individual under a PGD by a pharmacist authorised to use the relevant PGD who then delegates the supply of the medicines to another pharmacist, member of pharmacy team or pre-registration trainee pharmacist physically present with the individual.

A PGD is not suitable here. This is delegation of supply.

For further detail see Patient Group Direction (PGD) use in remote consultations

Preparation of IV contrast by an assistant for subsequent administration by radiographer under a PGD

This scenario considers whether a registered or unregistered healthcare professional can prepare IV imaging contrast prior to its administration to an individual by a Radiographer or Speech and Language Therapist under a PGD.

A PGD is not suitable here. This is delegation.

There is further advice available on preparation of contrast and PGDs available here