Supply of P and GSL medicines

Pharmacy (P) and General Sales List (GSL) medicines do not always need to be prescribed; there are several other mechanisms available for supply within dental practice.

The mechanism used in a specific situation depends on:

• who supplies the medicine
• whether the patient is receiving an NHS or private course of treatment

See Labelling and packaging medicines supplied by dental teams for labelling and packaging requirements for P and GSL medicines that dental team members must follow.

Dentists: P medicines

Regulation 223 of the Human Medicines Regulations (HMR 2012) exempts doctors and dentists from the requirement that P medicines must be supplied from a pharmacy. Dentists can therefore supply P medicines directly to their patients.

Dentists can also prescribe P medicines.

NHS patients

Dentists treating patients within an NHS course of treatment must comply with the terms of their NHS contract. NHS terms state that dentists may only supply patients with medicines:

• by prescription on an NHS prescription form (FP10D)
• directly, against a PSD, if ‘for immediate use before the issue of a prescription’ and the patient cannot get a prescription dispensed in time

Medicines that can be prescribed or supplied for immediate use are listed in the Dental Practitioners’ Formulary. The current list appears in the online BNF and part XVIIA of the Drug Tariff.

Considerations before prescribing P medicines:

• the NHS recommends that some P and GSL medicines and other healthcare preparations available over the counter are not routinely prescribed in primary care
• if prescribed, and prescription charges apply, some P medicines cost less to purchase from a pharmacy than a prescription charge – discuss with the patient
• P medicines not on the DPF list can be purchased from a pharmacy

Unless for immediate use dentists are unable to supply P medicines directly to patients receiving an NHS course of treatment. Dentists may not sell P medicines directly to patients receiving an NHS course of treatment.

Private patients

Patients undergoing a private course of treatment may be sold or supplied a P medicine. Sale or supply of P medicines cannot be delegated to any other member of the dental team.

Dental hygienists and therapists: P medicines

Dental hygienists and therapists can supply P medicines to patients receiving NHS or private courses of treatment using either Schedule 17 exemptions or Patient Group Directions (PGDs).

Schedule 17 exemptions

HMR 2012 Schedule 17 allows registered dental therapists and registered dental hygienists to sell or supply P medicines. They must be qualified to use the medicines and be acting in the course of their professional practice.

An e-learning programme, available via NHSE’s learning hub, aims to support dental hygienists and therapists to develop their competence in working under exemptions.

It is good practice to have a local policy or procedure for staff to follow when supplying medicines to patients. Protocols should address record keeping, storage, labelling, audit, training and assessment of competency. The Specialist Pharmacy Service (SPS) have developed a template protocol for local adaption for supply of P medicines. Organisations are responsible for ensuring the clinical and pharmaceutical content is appropriate. Templates should be approved through local governance processes.

Patient Group Directions (PGDs)

PGDs should not be used or developed for the supply of any P medicine used within the course of a dental hygienist’s or dental therapist’s professional practice. These should be sold or supplied via the HMR 2012 Schedule 17 exemption.

Practices currently using PGDs for these medicines should plan to change to working under Schedule 17 exemptions or PSDs. This will require training for staff to meet the requirement of being safe, effective and competent in the supply and administration of the specific medicines. PGDs for medicines falling within the Schedule 17 exemption cannot be renewed once they have expired (a maximum of 3 years from authorisation).

Dental nurses: P medicines

Dental nurses cannot work under PGDs or Schedule 17 exemptions and so cannot supply P medicines independently.

GSL medicines: sale from dental practices

The HMR 2012 (Regulation 221) do not restrict who can sell GSL medicines. A prescription or PGD is not required provided supply is from lockable premises and the medicine is supplied in an original unopened GSL labelled pack.

GSL medicines can be sold by any dental team member to a patient or member of the public, without first seeing the dentist.

It is good practice to have a local policy or procedure for staff to follow. Protocols should address record keeping, storage, labelling, audit, training and assessment of competency. SPS have developed a template protocol for local adaption for supply of GSL medicines. Organisations are responsible for ensuring the clinical and pharmaceutical content is appropriate. Templates should be approved through local governance processes.

Charging for medicines

NHS prescription charges apply to all medicines supplied during the course of NHS treatment. This also applies to all medicines supplied under a PGD or a Schedule 17 exemption.

However, the mechanism for collecting and reimbursing expenses associated with Schedule 17 supply has not yet been finalised. NHS England are considering how medicines for take-home use should be provided in NHS dentistry. In the meantime, they recommend that patients requiring such medicines are issued a prescription in line with established processes.

For P medicines, the patient:

• can be sold them by a dentist (private, not NHS)
• can be sold them by a hygienist or therapist (private, not NHS) working under a schedule 17 exemption
• can purchase them from a pharmacy

For GSL medicines, the patient:

• can be sold them by any member of the dental team
• can purchase them from a pharmacy or other retail outlet