Supply in dental practice

The Human Medicines Regulations 2012 (HMR 2012) state that prescription only medicines (POMs) may only be supplied against a prescription or Patient Specific Directions (PSD). Prescriptions and PSDs must be written by an appropriate practitioner (doctor, dentist or registered supplementary or independent prescriber).

Exemptions to Schedule 17 of the HMR 2012 have broadened mechanisms of supply in specific circumstances by dental hygienists and therapists. Where appropriate dental hygienists and therapists can use Patient Group Directions (PGDs).

Dentists

Regulation 223 of the HMR 2012 exempts dentists and doctors from the requirement that POMs must only be supplied against a prescription. However, NHS dental contracts restrict what can be supplied to patients receiving an NHS course of treatment.

Dentists cannot work under PGDs or Schedule 17 exemptions.

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 ‘required 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.

Supply for immediate use

Supply of medicines ‘required for immediate use before the issue of a prescription’ is rarely necessary as most areas have an extended-hours pharmacy.

There is no explicit rule regarding the quantity to supply ‘for immediate use’. Depending on the circumstances, it may be:

• sufficient to allow the patient to start treatment, with a prescription provided to obtain a further supply when they can get to a pharmacy
• a complete course appropriate for the presenting condition, as recommended by the NHS National out-of-hours formulary in the Drug Tariff

Medicines supplied this way must be labelled appropriately.

Private patients

Dentists may provide a private prescription or supply POMs directly to patients undergoing a private course of treatment and requiring a medicine to take home.

Dentists may prescribe or supply any medicine on a private prescription. Private dental prescriptions are not limited to medicines listed in the Dental Practitioners’ Formulary. However, dentists should only prescribe medicines to meet the identified dental needs of their patients.

For governance and labelling considerations when supplying medicines directly to patients, see Supplying medicines and medical devices: advice for dental teams and Labelling and packaging medicines supplied by dental teams.

Dental hygienists and therapists

Some POMs can be supplied to patients by dental hygienists and therapists working under a Schedule 17 exemption to the HMR 2012 or a PGD.

Supply of medicines under a Schedule 17 exemption or PGD is not prescribing.

Schedule 17 exemptions

The HMR 2012 Schedule 17 allows registered dental therapists and registered dental hygienists to supply a limited list of POMs. They must be qualified to use the medicines and be acting in the course of their professional practice.

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

POMs that may be supplied are listed in Part 2 of Schedule 17. In practice, of the 12 POMs listed, only nystatin suspension and sodium fluoride toothpastes 2800ppm and 5000ppm fluoride will be supplied. Inclusion of the other POMs reflects that Part 2 of Schedule 17 allows administration and receipt by wholesale of all medicines that are listed.

Supply can be made to patients receiving either NHS or private courses of treatment. POMs supplied via this exemption must be labelled appropriately.

Patient Group Directions (PGDs)

Dental hygienists and therapists can supply POMs under a PGD. PGDs enable the supply and/or administration of named medicines in the absence of a PSD, prescription or a legal exemption, for example Schedule 17. They can only be used in planned situations where clinical judgement outside the terms of the PGD is not required.

PGDs should not be used or developed for supply or administration of any of the POMs listed within Schedule 17. Practices currently using PGDs for these medicines should plan to change to working under Schedule 17 exemptions or PSDs.

PGDs for medicines listed in the Schedule 17 exemption cannot be renewed once they have expired (a maximum of 3 years from authorisation).

POMs supplied under a PGD must be labelled appropriately.

PGDs can be used to supply medicines to patients receiving either NHS or private courses of treatment. NHS patients can only be supplied with medicines listed in the Dental Practitioners’ Formulary.

Dental nurses

Dental nurses cannot work under a PGD or Schedule 17 exemptions and so cannot supply POMs independently.

Charging NHS patients for medicines

NHS prescription charges apply to medicines supplied during the course of NHS treatment. This applies to medicines supplied ‘for immediate use’ and 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.