Managing PGDs when healthcare organisations merge, cease to exist or services are transferred to a new provider

Jo Jenkins, Specialist Pharmacist (Patient Group Directions) SPS Medicines Use and Safety Division Source NHS PGD WebsitePublished

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.

To ensure continuity of patient care PGDs can be transferred from one organisation to another when services are transferred or organisations merged and used by the ‘new’ organisation for a defined, finite period.

Outlined below is how PGDs can be managed during periods of transition to ensure continuity of patient care whilst maintaining safety.

It is advised that early consideration should be given to the on-going and future use of PGDs prior to any mergers or service transfers occurring.

All PGDs must be adopted by the organisation(s) in which they are going to be used. 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 an appropriate medicines governance structure within the new organisation.

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.

It is advised that a nominated group or committee (e.g. local PGD oversight or working group, Medicines Management Board, Drugs and Therapeutics Committee or similar) is tasked to:

  • Ensure the 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.
  • Collate titles, version numbers and expiry/review dates of all the adopted PGDs centrally. 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.
  • Include PGDs in a formal paper or submission to the organisation’s Board that asks them to adopt all PGDs from the previous organisations with timescales for review.  Ensure all agreed adoptions and actions are recorded in the minutes.
  • Include a statement with reference to which group or committee will manage, review and authorise PGDs and their place within the organisation in the future.
  • Consideration should be given to the legal status of 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.
  • The nominated group or committee should agree a work plan to prioritise PGDs that are duplicated, are a priority for review and/or expire the soonest and work towards reviewing and transferring all adopted PGDs to the organisation’s template (as part of their review) at the earliest opportunity.

Organisations should ensure that practitioners are aware of transitional arrangements 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.