Transfer of PGDs
When healthcare organisations cease to exist, boundaries change, mergers occur or when services are transferred from one provider to another, consideration needs to be given to the transfer of PGDs to the new organisation. It is advised that early consideration should be given to the ongoing and future use of PGDs prior to any mergers or service transfers occurring.
To ensure continuity of care, PGDs can be transferred from one organisation to another when services are transferred, or organisations merged. If this happens, they must be adopted for use by the ‘new’ organisation for a defined, finite period.
Outlined below is advice on the process for appropriately managing PGDs during periods of transition to ensure continuity of care whilst maintaining safety and good governance. Depending on the organisation/s affected and the structure of services there may need to be cross boundary working as different parts of the PGD process may be the responsibility of different organisations (e.g. commissioner approves PGDs used by a provider but the provider is responsible for the development/review of PGDs in use) – all parties must be involved in this process
Where a legal body/service commissioner changes
All PGDs must be authorised by an appropriate legal body before they can be used. Where it is this legal body that ceases to exist/merges all PGDs must be adopted by the new legal body (organisation), forming part of the wider due diligence process. All PGDs adopted by the new organisation must be formally noted as described in the points below. Where a service is provided under PGDs by a commissioned provider this provider must be made aware of the PGDs transferring to the new organisation and must be involved in planning the review of PGDs in use (see below).
Where a service provider changes
Where it is the provider organisation changes all existing PGDs can be transferred to the new provider, with the agreement of the commissioner where relevant. All PGDs adopted by the new organisation must be formally noted as described in the points below.
Whether changes affect commissioner or providers, all organisations need to ensure they have an auditable process for managing the adoption of PGDs from any predecessor organisation and a formal plan of how the adopted PGDs will be reviewed and updated to bring them into line with the new organisation’s PGD process and the timescale this will be achieved over.
This needs to be considered at the earliest opportunity and relevant resources should be allocated to achieve this.
Some organisations may be faced with a large number of PGDs which will require dedicated resource and expertise to consider, review and submit for adoption. This requires as a minimum a senior pharmacist, a senior doctor and senior nurse/health professional representing the staff group(s) operating under the PGD and requires an appropriate medicines governance structure within the new organisation.
It is advised that a nominated governance group or committee (e.g. local PGD oversight or working group, Medicines Management Board, Drugs and Therapeutics Committee or similar) is tasked to undertake/oversee the following:
Collate titles, version numbers and expiry/review dates of all the adopted PGDs in a single document. During the interim period when organisations merge, more than one PGD for the same medicine(s) and indication(s) may be being used – consideration should be given to potential safety or governance issues. Agree a dated work plan to review and transfer all adopted PGDs to the organisation’s PGD template; prioritise PGDs that are duplicated, are a clinical or pharmaceutical priority for review and/or expire the soonest. Consider if auditing of PGD use is required. If PGD expiry date extensions are considered there is further advice available Extension of expiry date of a Patient Group Direction (PGD)
Legal status of organisations
Consider the legal status of all involved organisations and if the organisations involved are able to authorise new or updated PGDs or if this will need to be discussed with service commissioners
See Patient Group Directions in Complex Commissioning Scenarios and Authorisation of Independent Healthcare Provider (IHP) PGDs for NHS and public health commissioned services for further information.
Systems and processes
Ensure relevant systems and processes are in place for the review, development, authorisation and implementation of PGDs and for the adoption of transferred PGDs to comply with the legal framework and any associated national guidance.
Formally request in a submission to the organisation’s Board the agreement to adopt all listed PGDs with timescales for review. Ensure all agreed adoptions and actions (including any extension of expiry dates) are recorded in the minutes and include a statement detailing which group or committee will be responsible for the management, review and authorisation of PGDs within the organisation.
Organisations should ensure that practitioners working under PGDs are aware of transitional arrangements (as outlined above) and advise them to continue to practice only under the PGD(s) to which they were originally authorised to work under until otherwise advised. Organisations must ensure that appropriate training is available to staff operating under PGDs as detailed in each PGD and that this continues during any transitioning of services.