Patient Group Direction use by temporary/provisional professional registrants

In response to the COVID-19 pandemic the Nursing and Midwifery Council (NMC), the Healthcare Professionals Council (HCPC) and the General Pharmaceutical Council (GPhC) have opened temporary and/or provisional registers to register professionals who have either returned to their profession or are students awaiting final examinations/assessments.

Patient Group Directions should only be used where this offers an advantage for patient care, without compromising patient safety, and where there are clear governance arrangements and accountability.

The NMC, HCPC and GPhC have advised us of the following regarding Patient Group Directions (PGDs) use by these registrants only where individuals have been locally assessed as competent to operate under a PGD:

 

Nursing and Midwifery Council (NMC)

Registration NMC position regarding PGD use
Nurses/Midwives who left the permanent register up to three years ago have joined the temporary register and have no conditions of practice May operate under PGDs if locally assessed and competent to do so and have undertaken the appropriate training.
Overseas nurses or midwives with temporary registration who have yet to take their final OSCE and nurses or midwives who lapsed registration between 4 and 5 years ago, who have joined the temporary register and have conditions of practice in place May operate under PGDs if locally assessed and competent to do so and have undertaken the appropriate training.

 

Where a PGD is used by an appropriately trained and assessed nurse on the NMC temporary register with conditions of practice in place the responsibility for the entire episode of care including the decision to administer or supply a medicine under the PGD would lie solely with the nurse or midwife with temporary registration – they must not act in this role under the direction of any other person.  See also the following FAQs – Can supply or administration be delegated to another practitioner under a PGD? and Can registered health professionals who are trainee injectors , administer injections under PGD whilst being supervised?

Healthcare Professionals Council (HCPC)

Registration HCPC position regarding PGD use
Former registrants who had de-registered within the last three years and have joined the temporary register Anyone on the temporary register (whether they be a returning former registrant or a student), with the exception of annotations (e.g. prescribing), is entitled to the same medical entitlements as a registrant in the same profession on the permanent register. This means temporary registrants who were students can administer via PGDs without supervision if their profession has this right. However, they should only do so if they feel they have the required skills, knowledge and experience.
Final year students, on UK approved programmes, who had completed all their work-based learning requirements and have joined the temporary register

(Note this register is due to close by the end of September 2020.  Therefore students currently on the temporary register will need to obtain full registration in order to continue to be entitled to use their protected titles and therefore PGDs)

As above noting that former third year students should consider whether they have enough training and experience to start practising in this area.

 

Medical entitlements cannot be delegated so students are unlikely to have much experience, if any, in these areas.

 

Where a PGD is used by an appropriately trained and assessed professional on the HCPC temporary register the responsibility for the entire episode of care including the decision to administer or supply a medicine under the PGD would lie solely with the temporarily registered professional – they must not act in this role under the direction of any other person.  See also the following FAQs – Can supply or administration be delegated to another practitioner under a PGD? and Can registered health professionals who are trainee injectors , administer injections under PGD whilst being supervised?

General Pharmaceutical Council (GPhC)

Registration Position regarding PGD use
Temporary register – pharmacists who had voluntarily removed themselves or were removed for non-renewal from the GPhC register in the last three years and did not have Fitness to Practise issues, who have joined the temporary register. May operate under PGDs if locally assessed and competent to do so and have undertaken the appropriate training.
Provisional registration for pharmacists (pre-registration pharmacists awaiting final examination). May operate under PGDs if locally assessed and competent to do so and have undertaken the appropriate training to be able to meet the service requirements to deliver the service safely.  The employer should be able to confirm whether the registered pharmacy premises is contractually able to deliver any given PGD, and if so, what the terms of the PGD require.

 

Provisionally-registered pharmacists must also be acting under the guidance and support of their senior pharmacist, who must be available to be contacted if the provisionally-registered pharmacist needs support or guidance.

 

However where a PGD is used by an appropriately trained and assessed professional on the GPhC provisional register the responsibility for the entire episode of care including the decision to administer or supply a medicine under the PGD would lie solely with the provisionally registered pharmacist – they must not act in this role under the direction of any other person.  See also the following FAQs – Can supply or administration be delegated to another practitioner under a PGD? and Can registered health professionals who are trainee injectors , administer injections under PGD whilst being supervised?

 

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