Delegation and PGDs

Legislation does not allow delegation under a PGD. This is because within the legislation, PGD use is permitted under an exemption to Regulations 214, 220 and 221 of the Human Medicines Regulations 2012 (HMR 2012). These exemptions cannot be further delegated.

National guidance on delegation

The following national guidance is available relating to delegation under Patient Group Directions (PGDs).

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

The Medicines and Healthcare Regulatory Agency (MHRA) has confirmed 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 HMR 2012 Schedule 19, Regulation 238.

Use of a PGD

Authorisation to use a PGD cannot be transferred or delegated to any other person. Each individual needs to be separately authorised to operate under the PGD.

For example, it is not suitable for a pharmacist to delegate their authorised use of operating under a PGD to another pharmacist, such as a locum, on their day off. Both will need to be individually authorised to operate under the PGD.

Administration of injectable medicines

Only the professional working under the PGD or the individual themselves can administer an injectable medicine supplied under a PGD. A PGD is suitable if the individual will self-administer the injections. For example, low molecular weight heparin being supplied to individuals in a pre-operative assessment clinic.

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 professional to administer, a prescription or Patient Specific Direction from a prescriber will be required to authorise the administration.

Administration of non-injectable medicines

If the PGD is for supply of a non-injectable medicine only, then it can be given to the individual for self-administration or for administration by another appropriate person with the individual’s consent.

The law requires that administration of the supplied medicine is in accordance with the PGD. So, the PGD must specify that the medicine is supplied for subsequent administration and it is labelled appropriately.

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 professional making the supply. Medicines that are supplied for subsequent administration outside the clinic setting must be appropriately labelled and contain a patient information leaflet (PIL).

All relevant documentation must be completed by the professional making the supply under the PGD, including any clinical records in line with local policy, as must associated administration records where relevant.

Administration in another care setting

Where a non-injectable medicine is supplied under a 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.

Individuals authorised by their employing organisation to subsequently administer medicines supplied under the PGD (such as a nurse or healthcare support worker) 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.

Examples of permitted scenarios

The following are examples of specific tasks relating to the administration of non-injectable medicines that can be fulfilled by individuals other than the professional working under the PGD.

Administration of a medicine from a pre-labelled pack

Where a registered professional supplies a medicine as a pre-labelled pack for a non-injectable medicine using a PGD, another healthcare professional can administer the medicine if necessary.

Administration by an individual from the same or different organisation

A healthcare worker working for the same, or different, organisation to the one employing the professional making the supply, administers the non-injectable medicine.

An example is where a community nurse supplies the medicine under a PGD for subsequent administration by a care home worker. Such as when oseltamivir is supplied to an individual living in a care home by an NHS community nurse under a PGD, and is subsequently administered by a care home worker.

Administration in an inpatient hospital environment

An appropriate registered healthcare professional in an inpatient hospital environment uses a PGD to supply a medication which will then be administered. This should not be routine practice but reserved for use where it is locally deemed necessary to improve clinical care or safety.

An example 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.

Administration of the nasal live attenuated influenza vaccine

The administration of the nasal live attenuated influenza vaccine (LAIV) by a nursing associate after it has been supplied to a child by a nurse working under a PGD (where the PGD states the supply is for subsequent administration). Guidance has been provided by the Royal College of Nursing that LAIV does not need to be labelled if it is administered to the individual before they leave the clinic setting.

Related reading

Training

The following training-type scenario provides an example to help interpret the law into practice.

Practising injection technique

This scenario relates to a student nurse practising 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 states that PGDs are not suitable for health professionals who are undergoing relevant training, such as when administering intramuscular injections.

Use of PGDs by trainee registered healthcare professionals contains further guidance from SPS.

Supply

The following are examples of delegation of supply and therefore are not allowed under a PGD.

Assembling and supply ready for posting medicines

A clinic administrator assembling a supply of bowel cleansing medication, ready to be posted to an individual after clinical assessment by a nurse operating under a PGD.

In this example, the healthcare professional undertaking the clinical assessment is also required to assemble the supply for the individual. Patient Group Direction use in remote consultations contains further advice on posting medicines supplied under a PGD.

Community pharmacy supply

Delegated supply by a pharmacist

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.

Here, the pharmacist must assess the individual and must also supply the medicine according to the PGD. An authorised registered healthcare professional should, when supplying under a PGD, personally make the supply to the individual at the time of consultation. The supply cannot be delegated to another person following assessment by the authorised healthcare professional. However, the assistant could gather background information to support the pharmacist’s assessment and provide additional information to the individual (such as details of support services).

Delegated supply by a nurse

A nurse assessing an individual under a PGD who then directs the individual to a community pharmacy to obtain the supply (via a voucher).

In this example, the nurse may direct an individual 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 individual and is satisfied that an appropriate medicine is being supplied. The pharmacist would be responsible for the decision to supply the medicine.

Preparation of IV contrast

A registered or non-registered healthcare professional prepares intravenous (IV) imaging contrast prior to its administration to an individual by a radiographer or speech and language therapist under a PGD. This is not permitted. contains further information.

Remote assessment

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 or member of pharmacy team physically present with the individual. This is not permitted. Patient Group Direction use in remote consultations contains further information.

Video explainer

This video outlines the reasons why delegation of practice is not permitted when supplying and/or administering medicines under PGDs and how this affects their use.

Update history